In assessing contributions, the OECD distinguishes between low-value activity and other CCAs. In cases where activities within a CCA are of low value (definition 7.44 of oecd guidelines for 2017), the OECD notes, for practical reasons, that contributions to the cost of acquisition can be assessed since, in such cases, the value of services is close to the respective costs. As a result, a simple low CCA value acquisition activity is treated in a manner almost identical to a CCA administrative activity according to the OECD concept and according to the concept of the (former) German tax authorities. The agreement may include provisions for compensation and/or changes to the contribution allocation after a reasonable period of time to reflect substantial changes in the proportion of benefits expected between participants; B.6.7.2. When an associated company joins a CCA, either at the beginning of the CCA or as a new participant after the CCA is commissioned, the related company may receive an interest in pre-existing contributions from other participants or for the realized benefits of the CCA created by those participants. This may include. B intangible assets, other rights and non-employees. Since the new participant acquires an interest in such benefits, the arm length principle requires the participant to provide an arm length payment to other participants who have created the existing value for an arm length payment for this transfer. The amount to be paid by a new member when the CCA is seized for existing benefits is called buy-in. B.6.4.5.
Although all contributions to value are assessed on the principle of arm length, it may be easier for participants to measure current contributions to thought costs. If this approach is adopted, the value attributed to existing contributions should recover the opportunity costs of ex ante`s obligation to pay through costs within the CCA. For example, a contractual agreement (i.e. the CCA) requiring existing staff to carry out work for the benefit of the CCA should reflect the opportunity costs of alternative research and development efforts (e.g. B the difference between the value of the use closest to the research and development staff versus the projected research and development costs) when the research and development carried out by the CCA must be assessed at costs.