| 英文摘要 |
Cost Contribution Agreements refers to the agreement that signed by both side which declare usufruct and undertaking of activity cost from intangible assets development and assign or labor activity in-volved, and it requires that the transfer-pricing should follow the Arm's Length Principle. The core of Transfer-Pricing in Cost Contribution Agreements is the matching between costs and revenue, which makes considerations of profit contribution factor particularly important. Cost Contribution Arrangements itself contains the Arm's Length Principle. As the Arm's Length Principle guide the Transfer-Pricing, and the factor of Transfer-Pricing is the core measure contribution to profit, so it obtained that the factors of Cost Contribution Arrangements are the associated enterprises, the tax authorities as well as the cost & benefit matching principle. In order to consolidate tax base, Tax authorities demand Transfer-Pricing to follow the Arm's Length Principle. The tax authorities demand associated enterprises Transfer-Pricing follow the Arm's Length Principle for consolidating the base. On the other hand, transnational corporation also have to follow it in pursuit of profit maximization. This research examines whether the transfer pricing regulations in Taiwan are sufficient or not. It focuses on lack of regulations pertaining to Cost Contribution Agreements (CCA) in Taiwan. With the references to foreign legislations and cases, the research further discusses the legislation defects and provides suggestions for Taiwan's legislatives as to enactment or enforcement of related regulations in the future. This framework covers the following main items: definition of a CCA, reasonably anticipated benefits, changes in participants and the termination of CCAs, adjustments by tax administrations, tax treatment of CCAs, elements of a CCA, and administration of tax collection. |
