R&D is typically a source of value and differentiation for multinational enterprises (MNEs). In an intra-group context, MNEs with cross-border operations need to consider the different options available with respect to R&D structuring and financing among the different group entities involved.

In this article from Bulletin Crédit Impôt Recherche, NERA Director Emmanuel Llinares and Vice President Sébastien Gonnet explain how intra-group R&D structuring and financing pose significant consequences for MNEs, not only from tax and transfer pricing angles but also from operational and financial angles. As such, the authors caution, risks and opportunities in connection with R&D structuring and financing must be reviewed carefully.

This article first appeared in the Bulletin Crédit Impôt Recherche, a publication of Grande Armée Conseil, a company specialized in R&D valuation, in connection with certain specific French tax incentives.