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Contract Research and Development

In: Intangibles in the World of Transfer Pricing

Author

Listed:
  • Richard Schmidtke

    (Deloitte GmbH)

  • Benjamin Protte

    (Paul Hartmann)

  • Janis Sussick

    (Deloitte GmbH)

Abstract

Outsourcing of R&D tasks to specialized legal entities within a multinational enterprise is a commonly observed practice. This chapter discusses contract R&D setups, a popular method for aligning a transfer pricing structure with intercompany R&D outsourcing. This chapter describes the core features of contract R&D structures and establishes that in a typical setup the principal entity should be in control of all value-adding strategic functions and bear all material R&D risks. However, the contract R&D service provider’s role should be limited to routine functions and it should bear only limited risks. Such a setup typically entitles the R&D principal to directly own any intangibles resulting from successful R&D activities and to capture all returns that are generated based on these intangibles. This chapter also discusses the implications of new OECD recommendations on the arm’s length profit attribution and describes commonly observed pitfalls related to contract R&D.

Suggested Citation

  • Richard Schmidtke & Benjamin Protte & Janis Sussick, 2021. "Contract Research and Development," Springer Books, in: Björn Heidecke & Marc C. Hübscher & Richard Schmidtke & Martin Schmitt (ed.), Intangibles in the World of Transfer Pricing, edition 1, pages 199-213, Springer.
    • Handle: RePEc:spr:sprchp:978-3-319-73332-6_11
    DOI: 10.1007/978-3-319-73332-6_11
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