Cost Allocation Agreements

The costs of SVAS may be allocated, on the basis of one or more appropriate allocation keys, among all group members from whom such services can reasonably be expected (on a category basis, without the need to demonstrate actual benefit on an individual basis). The profit premium (if necessary) can be set at 5% and should not be evaluated. (i) technology transfer agreements (these contracts are often reimbursements of administrative costs and not of technical services); In Brazil, it can be said that reimbursements under cost-sharing agreements concluded by domestic enterprises are not subject to taxation under the IRPJ/CSLL, PIS/COFINS and ISS, provided that certain conditions are met and that these expenses are deductible or allow credits in respect of the taxes in question.

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