Whatever the method used to evaluate participants’ relative shares of expected benefits, adjustments to the measure used may be necessary to account for differences between the respective shares of expected and actual benefits received by the participants. The CCA should require periodic reassessment of contributions vis-à-vis the revised share of benefits to determine whether the future contributions of participants should be adjusted accordingly. Thus, the allocation key(s) most relevant to any particular CCA may change over time leading to prospective adjustments. Such adjustments may reflect either the fact that the parties will have more reliable information about foreseeable (but uncertain) events as time passes, or the occurrence of unforeseeable events.
TPG2017 Chapter VIII paragraph 8.22
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Allocation key, CCA/CSA, Cost Contribution Arrangement (CCA), Cost Sharing Arrangement (CSA), Periodic reassessment
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