iii) The indirect basis for measuring expected benefits. The indirect basis for measuring the expected benefits of participating in a qualified cost-sharing agreement is as follows: in 1995, cost-sharing agreements (ASCs) were put in place and caused controversy from the outset. A CSA is a contractual agreement between entities belonging to the same multinational group, which allows companies to share the costs and risks associated with the development, production or collection of assets. Companies with assets related to the R D or technology, such as pharmaceutical companies or software, have generally entered into such an agreement. (1) In general. For the purposes of this section, a participant is a controlled subject who meets the requirements of this paragraph (c) (1) (controlled participant) or a uncontrolled subject participating in the cost-sharing agreement (uncontrolled participant). The definitions of controlled and uncontrolled subjects are contained in the provisions of S. 1.482-1 (i) (5). A controlled subject can only be a controlled participant if he – (i) in general. The share of a member controlled in intangible development costs for a taxable year corresponds to its intangible development costs for the taxable year (in accordance with point d) of this section, divided by the sum of intangible development costs for the taxable year (according to paragraph (d) of this section) of all controlled participants.
The parties agree to cooperate in facilitating customers` connection to the regional.B river system. To the extent that the contracting parties own land or land interests, the contracting parties continue to provide fee-free facilities, in accordance with the cost-sharing agreement, to the extent necessary to connect customers to the regional hydra system, including extensions and additions to the county distribution system. ARTICLE 15 – LIMITED OF WAIVER OF SOVEREIGN IMMUNITY A. (h) Character of payments made under a qualified cost-sharing agreement – To verify these features – Check these features. , the agreement itself and its implementation by the parties must be taken into account, which could have different tax effects. (B) Sale. The sales of each controlled participant to activities in which registered intangible assets are operated can serve as an indirect basis for measuring expected profits. This valuation base will be more reliable as each controlled participant expects a similar increase in net income or a decrease in net loss attributable to intangible assets covered by a dollar of revenue. This is most likely to occur when the valuation costs of covered intangible assets are not significant relative to the revenues generated or when the main effect of the use of covered intangible assets is to increase the revenues of the controlled participants (. B, for example, a price premium for the products they sell) without significantly affecting their costs.
It is unlikely that the sales of each controlled participant will provide a reliable basis for measuring benefits unless each controlled participant works at the same market level (for example. B, manufacturing, distribution, etc.). Therefore, it is clear that either an effort, cost or contribution agreement is made by companies to share and allocate the costs or expenses incurred by one of them, to the benefit of all the companies in the group involved in the production of goods, services or rights.