Certain Important Aspects of Cost Contribution Arrangements in Financial Management
Cost contribution arrangements (CCAs) and Cost
sharing agreements (CCAs) belong to the tools of modern finance
management. Costs spend by associated enterprises on developing
producing or obtaining assets, services or rights (in general -
benefits) are used for tax optimizing too. The main purpose of joint
research and development, producing or obtaining benefits is to
lower these costs as much as possible or to maximize the benefits. In
this article is mentioned the problematic of transfer pricing and arm's
length principle with connection of CCAs, CSAs. Next, there is
mentioned how to settle participation shares of the total cost and
benefits contributions with respect to the OECD Transfer pricing for
MNEs Guidelines and with respect to other significant regulations.
[1] J. Valach, "Investi─ìn├¡ rozhodov├ín├¡ a dlouhodobé financov├ín├¡." 2nd
edition (revised), Prague, Ekopress, s.r.o., 2006.
[2] P. Mař├¡kov├í, M. Mař├¡k, "Diskontn├¡ m├¡ra pro v├¢nosové oceňov├ín├¡
podniku", Prague, Oeconomica, 2007.
[3] OECD "Transfer Pricing Guidelines for Multinational Enterprises and
Tax Administrations", OECD Publications, Paris, 1995, 1997, 2009.
[4] M. Markham, " The Transfer Pricing of Intangibles", Hague, Kluwer
Law International, 2005.
[5] Australian Government - Australian Taxation Office "Taxation Ruling
TR 2004/1 Income tax: international transfer pricing - cost contribution
arrangements" 2004.
[6] United States Treasury Regulations, sec. 1.482-7:
http://law.justia.com/us/
[1] J. Valach, "Investi─ìn├¡ rozhodov├ín├¡ a dlouhodobé financov├ín├¡." 2nd
edition (revised), Prague, Ekopress, s.r.o., 2006.
[2] P. Mař├¡kov├í, M. Mař├¡k, "Diskontn├¡ m├¡ra pro v├¢nosové oceňov├ín├¡
podniku", Prague, Oeconomica, 2007.
[3] OECD "Transfer Pricing Guidelines for Multinational Enterprises and
Tax Administrations", OECD Publications, Paris, 1995, 1997, 2009.
[4] M. Markham, " The Transfer Pricing of Intangibles", Hague, Kluwer
Law International, 2005.
[5] Australian Government - Australian Taxation Office "Taxation Ruling
TR 2004/1 Income tax: international transfer pricing - cost contribution
arrangements" 2004.
[6] United States Treasury Regulations, sec. 1.482-7:
http://law.justia.com/us/
@article{"International Journal of Business, Human and Social Sciences:50343", author = "Tomáš Brabenec", title = "Certain Important Aspects of Cost Contribution Arrangements in Financial Management", abstract = "Cost contribution arrangements (CCAs) and Cost
sharing agreements (CCAs) belong to the tools of modern finance
management. Costs spend by associated enterprises on developing
producing or obtaining assets, services or rights (in general -
benefits) are used for tax optimizing too. The main purpose of joint
research and development, producing or obtaining benefits is to
lower these costs as much as possible or to maximize the benefits. In
this article is mentioned the problematic of transfer pricing and arm's
length principle with connection of CCAs, CSAs. Next, there is
mentioned how to settle participation shares of the total cost and
benefits contributions with respect to the OECD Transfer pricing for
MNEs Guidelines and with respect to other significant regulations.", keywords = "Arm's length principle, Cost contribution arrangements, Cost sharing agreements, Reasonable anticipated benefits, Relevant costs, Transfer prices.", volume = "4", number = "7", pages = "1552-12", }