Tax implications for Swiss taxpayers of Altera vs. Commissioner decision of the US Tax Court of 7 June 2019

A cost-sharing arrangement (CSA) is an intra-group agreement under US American law which is defined and strictly regulated in the US Treasury Regulations. This agreement is the result of both parties' commitment to share the costs, risks and benefits of the development of one or more intangible assets. The costs are shared proportionately, based on each party's expected profit from the use of the developed assets according to a contractually agreed profit distribution.

Questions and answers in connection with cost sharing arrangement

Here you will find information on various transfer pricing topics in connection with cross-border transactions. This information is intended to provide clarification on selected issues. It is general in nature and cannot be used as the sole basis for the tax assessment of a specific fact pattern.


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Last modification 11.12.2024

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