Although cost-sharing arrangements (CCA) have been used by MNEs as part of tax planning strategies for years, recent regulatory developments have subjected CCAs to intense scrutiny. Under these new regulations, certain intercompany transfers of intangibles – broadly defined as transfers of any profit-driving assets and capabilities – may have to be valued under a framework where all of the benefits from the transferred intangibles, including the benefits from subsequent development of these intangibles, accrue to the original intangibles developer. ACL’s experts assist clients in addressing the new requirements of these regulations and in adapting the valuations applied for existing arrangements and restructuring transactions to the new valuation paradigms.

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