Have you ever faced a transfer pricing audit and realized your intercompany “policy” isn’t the same as a legally solid agreement? Or wondered how to draft an APA, CCA, safe harbor position, or service contract that actually aligns with OECD Guidelines and BEPS expectations? Transfer pricing is often won—or lost—in the paperwork: the clauses you choose, the assumptions you document, and the way you translate pricing logic into enforceable terms. Transfer Pricing Agreements: A Practical Guide shows you how to turn transfer pricing strategy into clear, defensible agreements that work in the real world. Why This Book? Because many disputes don’t start with the numbers—they start with weak agreements: unclear scopes, missing benefit tests, vague royalty language, inconsistent risk allocation, or documentation that fails to match actual conduct. This book helps you structure transfer pricing agreements that are coherent, audit-ready, and aligned with modern compliance standards—without drowning in theory. What You’ll Find in This Book Foundations of Transfer Pricing Agreements (Chapter 1): What transfer pricing agreements are, why they matter for compliance, and how they support both MNE governance and tax authority certainty. - Product Supply & Intangibles in Practice (Chapters 2–3): How to structure intercompany goods contracts and IP licensing (technology, trademarks, know-how), set defensible pricing/royalties, and manage valuation pressure under OECD standards—backed by dispute lessons and key cases. - Cost Contribution & Intra-Group Services (Chapters 4–5): Building CCAs and service agreements that align costs, benefits, and risks; choosing workable pricing mechanisms; documenting proportionality and benefit tests; and avoiding “duplicative/non-existent service” pitfalls. - Intercompany Financing (Chapter 6): Designing loans and financial arrangements, determining arm’s length interest rates, and addressing thin capitalization and BEPS-related concerns. - APAs & Safe Harbors to Reduce Uncertainty (Chapters 7–8): How APAs are negotiated and monitored, what “critical assumptions” really mean, and how to use safe harbor regimes (including industry-specific approaches) with real-world case insights. - Dispute Resolution & Cross-Border Coordination (Chapter 9): How MAP works in transfer pricing disputes, how BEPS Action 14 shapes cooperation, and practical steps to prevent or relieve double taxation. - Modern Deal Structures & Drafting Best Practices (Chapters 10–12): Transfer pricing in joint ventures and partnerships, digital and platform-based arrangements, cloud and tech-driven cost sharing, the implications of Pillar One and Two—and a final toolkit for drafting and negotiating stronger, audit-ready agreements. Who This Book Is For This book is for tax and finance professionals, in-house legal teams, transfer pricing managers, advisors, auditors, and controllers who draft, review, approve, or defend intercompany agreements—and for anyone responsible for OECD/BEPS-aligned documentation and risk management across borders. About the Author Dr Sergey Mazol is an economist with a PhD in Economics and experience in global trade and tax regulation. He has advised international organizations including the OECD, WTO, and UNECE, and lectures on multinational corporation governance. As a member of the European Corporate Governance Institute (ECGI), Dr. Mazol’s work reflects his authority in corporate governance—bringing together academic rigor and practical insight for navigating the complexities of global transfer pricing.