Transfer Pricing and Intangibles by Oddleif Torvik;

Author:Oddleif Torvik;
Language: eng
Format: epub
Publisher: IBFD
Published: 2018-06-14T16:00:00+00:00

14.2.7.5. Platform contributions

All controlled participants must commit to and engage in platform contribution transactions (PCTs), to the extent that there are such contributions. 1368 In a platform contribution transaction, each controlled participant is obligated to make arm’s length payments (buy-in) to each controlled participant that provides a platform contribution. The entity that renders the platform contribution (typically, a unique, pre-existing intangible) is called the PCT payee, while the entity that must pay the platform contribution transaction payment (buy-in amount) is called the PCT payer. The author will, for the sake of simplicity, try to avoid these rather cumbersome terms when possible.

The regulations define a platform contribution as:

[…] any resource, capability, or right that a controlled participant has developed, maintained, or acquired externally to the intangible development activity (whether prior to or during the course of the CSA) that is reasonably anticipated to contribute to developing cost shared intangibles. 1369

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