Transfer Pricing and Intangibles
1. Aufl. 2019
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S. 123Structuring intangibles – panel discussion
Below is a summary of the panel discussion on Session 3. The summary was composed by Karol Dziwiński, research and teaching associate at the Institute for Austrian and International Tax Law of WU (Vienna University of Economics and Business).
The panel discussion featured representatives from Business (hereinafter MNE), Advisory (hereinafter Advisor), and tax authorities (hereinafter Tax Authorities).
Cost Contribution Arrangements (CCA) – post-BEPS. Is there a need for joint project groups, risk control, strategy reports, etc.? How to interpret the changes to CCAs made with BEPS?
Advisor: The changes made by the OECD in the BEPS project are rather “frustrating”, and the new requirements regarding CCAs are not practical at all. They will most likely result in CCAs disappearing in the practice of MNEs not because they are no longer needed but due to the fact that compliance with the new rules is almost impossible.
The first of the new rules is that qualified participants have changed and service companies, holding companies, and IP companies might no longer be a part of CCAs. The OECD has always justified this change due to certain abu...