As indicated in Section D. 1 of Chapter I, the delineation of the actual transaction undertaken forms the first phase in any transfer pricing analysis. The contractual agreement provides the starting point for delineating the actual transaction. In this respect, no difference exists for a transfer pricing analysis between a CCA and any other kind of contractual arrangement where the division of responsibilities, risks, and anticipated outcomes as determined by the functional analysis of the transaction is the same. The guidance on identifying the other economically relevant characteristics is equally applicable to CCAs as to any other type of contractual arrangement, including an assessment as to whether the parties contractually assuming risks are actually assuming these risks based on the framework for analysing risk set out in paragraph 1.60 of these Guidelines. As a consequence, parties performing activities under arrangements with similar economic characteristics should receive similar expected returns, irrespective of whether the contractual arrangement in a particular case is termed a CCA. However, there are specific characteristics of CCAs that warrant special consideration ...

As indicated in Section D. 1 of Chapter I, the delineation of the actual transaction undertaken forms the first phase in any transfer pricing analysis. The contractual agreement provides the starting point for delineating the actual transaction. In this respect, no difference exists for a transfer pricing analysis between a CCA and any other kind of contractual arrangement where the division of responsibilities, risks, and anticipated outcomes as determined by the functional analysis of the transaction is the same. The guidance on identifying the other economically relevant characteristics is equally applicable to CCAs as to any other type of contractual arrangement, including an assessment as to whether the parties contractually assuming risks are actually assuming these risks based on the framework for analysing risk set out in paragraph 1.60 of these Guidelines. As a consequence, parties performing activities under arrangements with similar economic characteristics should receive similar expected returns, irrespective of whether the contractual arrangement in a particular case is termed a CCA. However, there are specific characteristics of CCAs that warrant special consideration ...