Contractual arrangements are a critical part of a defensible transfer pricing framework. As tax authorities continue to scrutinize intercompany transactions, agreements must accurately reflect the commercial and economic reality of the business. Poorly drafted, outdated, or inconsistent agreements can significantly increase transfer pricing risk and weaken a taxpayer’s position during an audit.

This session explored the role of contractual arrangements in transfer pricing, highlighting common legal pitfalls and practical lessons from recent case law to help organizations strengthen governance and improve audit readiness.