Pool Concept

Richard Schmidtke (), Benjamin Protte and Janis Sussick ()
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Richard Schmidtke: Deloitte GmbH
Benjamin Protte: Paul Hartmann
Janis Sussick: Deloitte GmbH

A chapter in Intangibles in the World of Transfer Pricing, 2021, pp 215-229 from Springer

Abstract: Abstract Research and development cost contribution arrangements (“R&D CCA”) are a commonly used setup for implementing complex R&D projects within multinational groups from a transfer pricing perspective. This chapter starts by describing the advantages and disadvantages of R&D CCAs. Then we describe the criteria for membership in an R&D CCA and how these have narrowed as a result of the OECD BEPS project. To perform the activities of an R&D CCA, the participants contribute R&D efforts and resources, as well as existing intangibles. These contributions need to be valued and as necessary balanced. Further valuations and balancing payments become necessary when participants enter the R&D CCA later on or leave before the project is complete. We guide the reader through all these stages and describe the relevant regulatory background. At each stage, we illustrate these regulations with a practical example of an R&D CCA.

Keywords: Transfer pricing; Cost contribution arrangement; R&D; Intangibles; Pool concept; CCA (search for similar items in EconPapers)
Date: 2021
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Persistent link: https://EconPapers.repec.org/RePEc:spr:sprchp:978-3-319-73332-6_12

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DOI: 10.1007/978-3-319-73332-6_12

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