The LCN Legal Podcast

Hosted by LCN Legal

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Mar 2026

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The LCN Legal Podcast brings you expert views and analysis of the legal aspects of transfer pricing compliance. Our focus is always on real-world, practical insights that you can apply in your everyday work. We often feature interviews with experts within and around the international transfer pricing community.

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20 recent

March 29, 2026Episode 2049 min

Episode 20: Enterprise AI in Practice with Candy Liu, Strategic Global Account Lead at Microsoft

What does enterprise AI actually look like in practice?In this episode, Xiaofang and Paul speak with Candy Liu, Strategic Global Account Lead at Microsoft, about how large organisations are adopting AI in the real world.From Microsoft Copilot and AI agents to hackathons, governance, and change management, Candy breaks down what works, what fails, and where businesses should start.They discuss why AI adoption needs leadership support, how teams can use AI to improve productivity and reduce low-value admin, and why the best results come from focusing on high-impact use cases instead of trying to make everything “AI-first” at once.The conversation also explores what smaller businesses can learn from enterprise teams, how finance and customer service functions are already benefiting from AI, and why the future of work will involve managing both human and digital resources.A practical episode for anyone trying to use AI more effectively at work.

August 29, 2024Episode 1933 min

Episode 19: Practical challenges when implementing Amount B, with Robin Hart

Paul Sutton talks to Robin Hart – a Principal in Charles River Associates’ Transfer Pricing Practice, based in the San Francisco Bay Area – about the current status of Amount B. With an expected start date of 1 January 2025, and many important factors still unclear, it is a very significant challenge for many multinationals.Paul and Robin’s discussion covers:A recap of what Amount B is intended to achieve, and progress so farA summary of the current situationWhat we know at this time, and some very significant questions that are still unansweredThe incentives for some countries not to adopt Amount B, and some of the practical consequences that might resultHow multinationals should already be preparingSome of the challenges for multinationals in implementing Amount BPossible longer-term developments, including the Amount B approach being extended to other transaction typesKey takeaways for MNEs who are affected by these issues.Want more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

February 2, 2023Episode 119 min

Target Margin arrangements

Target Margin is a frequently used transfer pricing model, and one which particularly lends itself to limited risk distribution arrangements. LCN co-founder Paul Sutton discusses the implications in detail.When Target Margin arrangements are most likely to be suitableThe two main options when drafting the pricing clause of the ICA, and how to choose which one to useThe importance of looking at the transaction from both a TP perspective and a legal one, and then reconciling the twoCommon mistakes, and how to avoid themWant more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

March 3, 2023Episode 211 min

HMRC v BlackRock: what should we learn?

In 2022, the UK Upper Tribunal’s judgment in HMRC v BlackRock sparked a lot of comment – and not a little consternation – around the transfer pricing community. LCN co-founder Paul Sutton discusses the implications in detail.How the case changes things, and how it doesn’tHow the Upper Tribunal’s position differed from the previous First-tier Tribunal judgmentThe most important implications for MNEs and their transfer pricing advisers.Want more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

November 1, 2023Episode 1129 min

Intra-group franchising arrangements, with Spencer Ho

Paul Sutton talks to Spencer Ho from RoyaltyStat, which recently became part of Exactera. RoyaltyStat is an industry-leading online database of royalty rates extracted from license agreements and interactive transfer pricing analytics.Paul and Spencer discuss a range of issues around intra-group franchising arrangements, including:a high-level perspective on how franchises work as between unconnected third partiesthe key documents involvedthe key elements of the financial arrangementswhat information is available for the benchmarking of intra-group franchise arrangementswhat factors transfer pricing practitioners should consider, in addition to the headline royalty rates.Want more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

August 2, 2023Episode 829 min

A corporate recovery perspective on related party transactions

Paul Sutton talks to Mark Supperstone, Managing Partner of the corporate restructuring specialists Resolve, about how an office-holder in a formal corporate restructuring process involving a UK entity would look at related party transactions in the period leading up to the restructuring.They also consider what implications this has for group structures, and what practical steps legal entity directors can take to protect their position and reduce the risk of personal liability.Applying the arm’s length principle to intercompany transactions within a multinational group can sometimes appear to be a theoretical exercise. But if individual entities or the group as a whole experience financial distress, related party transactions are likely to be subject to scrutiny in a much more pointed way. Office holders in formal insolvency proceedings may be under a statutory duty to investigate the conduct of legal entity directors in the months and years leading up to the insolvency, and directors may be exposed to personal liability or disqualification if they are unable to account for their decisions. Paul Sutton and Mark Supperstone discuss this scenario from the perspective of UK entities in financial distress, and consider key questions such as: The key legal duties of an administrator in a formal administration processThe first steps which an administrator would be likely to take on taking officeThe statutory duty on officeholders to investigate the conduct of directorsHow an administrator or liquidator would be likely to view transactions between the company in liquidation, and other members of the groupKey duties of legal entity directors, and the circumstances in which they may become personally liableThe practical steps which legal entity directors can take to minimise their exposure to personal liabilityThe importance of addressing a potential situation before it develops, and getting informal advice at an early stage.Want more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

August 22, 2023Episode 914 min

Germany’s ex ante price setting approach to TP, and the impact on intercompany agreements

Paul Sutton looks at the German Finance Ministry’s June 2023 update to its Administrative Principles on Transfer Pricing. The new version confirms some fundamental points that multinationals and transfer pricing professionals need to be aware of. Perhaps the most important is a very clear and specific position regarding ex ante price setting, and the need for intercompany agreements to be implemented in advance, not after the event.Germany’s 2023 update to its Administrative Principles on transfer pricing confirm that the key point in time for the application of the arm’s length principle is the date of conclusion of the relevant intercompany agreement, not the date on which the relevant transaction is performed. This is a crucial distinction, and of course presupposes that appropriate intercompany agreements have been put in place on an ex ante or price setting basis. Although this approach is consistent with the OECD Transfer Pricing Guidelines, it reflects a much clearer and more specific expression of the concept of risk allocation, price setting and the ‘playing out’ of risks and contractually delineated transactions. Clearly this has big implications for MNEs who are active in Germany, as it’s simply impractical to take one approach there and a completely different one in other territories. Paul Sutton looks at both the technical aspects and what it means in practice.Want more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

April 14, 2023Episode 439 min

Ongoing TP litigation in Australia, with Andy Bubb

An in-depth discussion by Paul Sutton and Melbourne-based tax disputes specialist Andy Bubb. They look at three cases that are currently ongoing in Australia: Pepsi, Singtel and Mylan. For each case, they: Review the current progress of the litigationAnalyse the specific issues in questionIdentify key learning points for transfer pricing professionals.Want more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

June 27, 2023Episode 723 min

The 5-step process for creating and implementing ICAs

Paul Sutton and Paul O’Regan discuss LCN Legal’s 5-step process for creating and implementing ICAs. This has been developed over many years, and is designed to ensure that in a tax audit, the group's ICAs will support its TP position.Paul Sutton explains the firm’s 5-step process for creating and implementing effective ICAs. In the course of explaining each stage in detail, he highlights the importance of: Ensuring that ICAs have legal substance, and integrating the legal considerations from the outsetUnderstanding the precise nature of the key transactions, and establishing the ‘legal anchor points’Working effectively with the wider team of TP professionalsDrafting that is brief and clear, using plain languageIdentifying and taking on board the needs of other stakeholdersLocalising agreements to reflect the needs of different countries and entitieEnsuring that directors have all the information they need to carry out their responsibilitiesCreating – and maintaining – a central online archive of agreements.Want more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

May 30, 2024Episode 1727 min

Episode 17: Operating model effectiveness, with Sam Barrett, Ernst & Young LLP

Paul Sutton talks to Sam Barrett – Managing Director, Americas Operating Model Effectiveness, which is part of the International Tax practice at Ernst & Young LLP – about operating model effectiveness and global value chain projects. What are they, what do they try to achieve, and how can they be implemented successfully?Paul and Sam’s discussion covers:What operating model effectiveness aims to achieve, and howThe typical drivers behind operating model effectiveness and global value chain projectsHow the tax and transfer pricing teams should be involvedThe role of non-tax functions such as IT, HR and LegalGeneral principles and methodologies that can be appliedHow to make sure that, after implementation, projects have actually achieved the intended resultsThe main challenges for multinational groups’ tax functions over the next yearKey takeaways for heads of tax and their advisers.Want more insights on transfer pricing, legal risk, and cross-border structuring?Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements