097. Transfer Pricing: Cost Contribution Arrangements In Germany

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In June of this year the OECD Tax Committee approved a new chapter VIII on cost contribution arrangements for addition to the 1995 OECD Transfer Pricing Guidelines. This has refocused attention on cost contribution arrangements (CCAs) as an instrument for the development of intangible assets. Three months prior to the OECD action, Professor Berndt R. Runge, a senior official in the German Federal Ministry of Finance who represents Germany vis-a-vis the OECD, published an article in Intertax entitled "The German View of Cost Contribution Arrangements". The similarities between the new OECD chapter on CCAs (cited below as "OECD Ch. VIII" with paragraph number) and Professor Runge's article indicate certain changes in the German position on CCAs. At the same time, it is evident that considerable differences continue to exist