Page 42 - Strategic Tax Planning for Global Commerce & Investment
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Cross Border Tax Planning Strategies
3. Shared Contract R&D Model
Under this model the R&D company carries out its R&D work
on behalf and for the account of various companies in the
“group” of companies of the multinational that will use the IP
resulting from the R&D. The R&D company is remunerated in
a similar manner to the “Contract R&D Model”, described
above, however, instead of a single company (the “IP
company”) owning the resulting IP, the beneficial and
economic ownership will be shared among the various
companies in the group that use it in their respective business.
4. Cost Sharing Agreement R&D Model
Under the “Cost-Sharing Agreement” R&D Model the various
companies of the multinational group agree that one or more of
them will carry out the R&D on behalf of themselves and of the
remaining companies on a basis of pre-agreed split of costs.
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