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Published in:
2021 | OriginalPaper | Chapter
Pool Concept
Authors : Richard Schmidtke, Benjamin Protte, Janis Sussick
Published in: Intangibles in the World of Transfer Pricing
Publisher: Springer International Publishing
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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.
