Tag: Transfers of interest in intangibles

§ 1.482-7(a)(3)(ii) Transfer of interest in a cost shared intangible.

/ CCA/CSA, CCA/CSA - methods for pricing, CCA/CSA changes in the membership, CCA/CSA contributions, CCA/CSAs for development, Contribution to value of intangibles, Intangibles, Transfers of interest in intangibles, US IRC Section 482 on Transfer Pricing, § 1.482-7 Methods to determine taxable income in connection with a cost sharing arrangement
If at any time (during the term, or upon or after the termination, of a CSA) a controlled participant transfers an interest in a cost shared intangible to another controlled taxpayer, the controlled participant must receive an arm’s length amount of consideration from the transferee under the rules of §§ 1.482-4 through 1.482-6 as supplemented by paragraph (f)(4) of this section regarding arm’s length consideration for a change in participation. For this purpose, a capability variation described in paragraph (f)(3) of this section is considered to be a controlled transfer of interests in cost shared intangibles ... Read more