Intercompany agreements for Cost Contribution Arrangements (CCAs) / Cost Sharing Arrangements (CSAs) are special for a number of reasons. One is that, more than any other transaction type, the arrangements just don’t exist without an appropriate legal agreement. Another is that the US Treasury rules are very prescriptive about what must be included in a CSA agreement, and they also specify that the arrangement must be recorded “in its entirety” in a document that the parties sign and date no later than 60 days after the relevant costs are first incurred.

To help corporates and their advisors manage the legal implementation of these arrangements better, we’ve produced a preliminary checklist for the legal implementation of CSAs / CCAs relating to intangibles. The checklist includes information required to meet the formal requirements listed in the relevant IRS regulations.

You can download your free copy of the checklist here. (This should download a Word version of the document automatically. If it doesn’t work for any reason, please email us at and we’ll send the checklist as an attachment.)

I hope you find it useful, and please feel free to share it with anyone else you think may appreciate it. The checklist doesn’t address the tax and economic analysis that is required for these arrangements, because we don’t advise on those aspects. We work alongside tax and TP advisers, both in-house and in private practice to ensure that arrangements like this are designed and implemented appropriately.

Of course, we would be delighted to help on the legal aspects of any arrangements of this nature which you or your colleagues might be considering, and we will be very happy to give a fee quote based on whatever initial information you have. Just send a brief email to us at, and we will be in touch to discuss your potential needs.