Research On Taxation Of Cost Contribution Arrangements Of Intangible Assets

Based on the rapid development of modern knowledge economy,the measurement of intangible assets in the company’s management is increasingly important,all walks of life are constantly strengthening the strength of intangible assets research and development and discussion.But the great risks and uncertainties make intangible assets R&D a bet for companies.The United States is the first country to appear cost-sharing agreement legislation.However,China’s legislative recognition of the cost contribution arrangements began in 2008.Cost sharing,risk sharing and benefit sharing were originally the prominent goals of the early cost contribution arrangements,but they were gradually used by some multinational companies to carry out undesirable profit transfer and reduce the global overall tax burden.The disputes between tax authorities and taxpayers in transfer pricing and other fields caused by intangible assets have never stopped,but become more and more intense.Driven by the overall environment and out of competition and benefit maximization,it is inevitable that enterprises in China use intangible assets cost contribution arrangements to avoid tax or multinational groups in developed countries use intangible assets cost contribution arrangements to erode China’s tax base.Therefore,this article selects the case about how Microsoft company tax cost contribution arrangements,clever use of intangible assets on intangible assets cost contribution arrangements as the research focus,which is based on several elements of cost contribution arrangements is the most important intangible assets,points out that the multinational corporation in the use of cost contribution arrangements at the time of research and development of intangible assets is often used method of tax avoidance.in this paper,and then clarify the OECD in the 2017 edition of transfer pricing and guide to the 2022 edition of transfer pricing guide on intangible assets cost contribution policy recommendations of the agreement,at the same time managing our cost contribution protocol in the different stages of development,and connecting with the current policies,procedures,cost contribution arrangements.The shortcomings and problems in the management of cost contribution arrangements in China are compared and analyzed.Finally,combined with specific cases and OECD recommendations,targeted and effective measures are constructed.It is expected that this paper will provide some reference for the tax management of the cost contribution arrangements of intangible assets in China.