NDLI: Cost Contribution Arrangements

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009

The Arm's Length Principle

Traditional Transaction Methods

Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes

Special Considerations for Intangible Property

Special Considerations for Intra-Group Services

Cost Contribution Arrangements

Appendix. Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/Final].

List of Annexes

Cost Contribution Arrangements

Content Provider	OECD iLibrary
Organization	OECD
Abstract	This chapter discusses cost contribution arrangements (CCAs) between two or more associated enterprises (possibly along with independent enterprises). There are many types of CCAs and this chapter does not intend to discuss or describe the tax consequences of every variation. Rather, the purpose of the chapter is to provide some general guidance for determining whether the conditions established by associated enterprises for a CCA are consistent with the arm's length principle. The tax consequences of a CCA will depend upon whether the arrangement is structured in accordance with the arm’s length principle according to the provisions of this chapter and is adequately documented. This chapter does not resolve all significant issues regarding the administration and tax consequences of CCAs. For example, further guidance may be needed on measuring the value of contributions to CCAs, in particular regarding when cost or market prices are appropriate, and the effect of government subsidies or tax incentives (see paragraphs 8.15 and 8.17). Further development might also be useful regarding the tax characterisation of contributions, balancing payments and buy-in/buy-out payments (see paragraphs 8.23, 8.25, 8.33 and 8.35). Additional work will be undertaken as necessary to update and elaborate this chapter as more experience is gained in the actual operation of CCAs.
Page Count	15
Starting Page	179
Ending Page	193
Language	English
Publisher	OECD Publishing
Publisher Date	2009-08-18
Access Restriction	Open
Subject Keyword	Finance and Investment Taxation Industry and Services Trade
Content Type	Text
Resource Type	Chapter

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