A very happy Independence Day to all of our readers with a USA connection. To mark the occasion, we’d like to share something that may help you to comply with the US Treasury rules concerning Cost Sharing Arrangements (CSAs), also known as Cost Contribution Arrangements (CCAs).
These rules are unusual in the world of intercompany agreements, because they are very prescriptive about what must be included in a CSA agreement. They also specify that the arrangement must be recorded “in its entirety” in a document that the parties sign and date no later than 60 days after the relevant costs are first incurred.
To help corporates and their advisors manage the legal implementation of these arrangements better, we’ve produced a preliminary checklist for the legal implementation of CSAs / CCAs relating to intangibles. The checklist includes information required to meet the formal requirements listed in the relevant IRS regulations.
You can download your free copy here.
The checklist doesn’t address the tax and economic analysis that is required for these arrangements, because we don’t advise on those aspects. (We work alongside tax and TP advisers, both in-house and in private practice, to ensure that arrangements like this are designed and implemented appropriately.)
I hope you find it useful, and please feel free to share it with anyone else you think may appreciate it.
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