Tax Study On Cost Contribution Agreement Of Intangible Assets

With the fast development of knowledge economy,intangible assets become more important than ever in many enterprises' commercial operating activity.However,enterprises face great R&D risk uncertainty,the earliest Cost Contribution Agreement(CCA)regulations came into being in the United States thereby.The first CCA rules of China was appeared in 2008.CCA,which should be shouldering the responsibility of "sharing cost and risk,sharing revenue",has been regarded as a "reasonable" tool to transfer profits and avoid tax by some MNEs.However,it just has compliance in the ratio of cost and revenue,not in economic essence.Based on the theories of economic man,substantial taxation and information asymmetry,this paper focuses on CCA of intangible assets.First of all,by introducing the relevant overview and theory of CCA and intangible assets,this paper lays the foundation for the follow-up research.Secondly,it mainly analyzes the core elements of CCA,and points out the common tax avoidance points when enterprises use the CCA in R&D activity,then combined with Microsoft case study,I focused on how Microsoft avoid tax by using CCA.Thirdly,I review the three stages of the development of CCA in China.According to the current laws and regulations of CCA in China,I explained how CCA works in tax authorities and enterprises,and analyzed the main problems in CCA.In the last chapter,according to the above questions,and combined with Microsoft case,I gave some relevant suggestions.I hope that this paper could provide a theoretical reference for perfecting the tax administration system of intangible assets of CCA in China.