By: admin On: September 10, 2021 In: Uncategorized Comments: 0

In one of these structures, the company that centralizes such joint activities will support the other companies that will participate in the allocation of associated costs and expenses. “It is possible to concentrate the control of expenditure related to centralized administrative support services in a single enterprise in order to subsequently establish the common management costs and expenses of enterprises that do not maintain the concentrated administrative structure. (i) technology transfer agreements (these contracts are often reimbursements of administrative costs and not of technical services); If one of the parties wishes to amend the agreement in the future, both parties should give their consent, and the initial agreement and amendments should be recorded in writing and signed by both parties. On the other hand, the Federal Office of Finance has generally taken a position on cost-sharing agreements concluded with companies established abroad by taxing the transfer via IRFONTE (15%), imports pis/COFINS (9.65%), cide (10%) and ISS. However, the decisions generally stipulate that, in some cases, they have not established an effective allocation, which explains the application of taxes. Conversely, the Federal Tax Office has recognised the deduction or entitlement to the credit in respect of such expenses and costs. Under such conditions, the subject still raises doubts and controversies. However, if there is an effective cost-sharing agreement with the respective controls, we believe that the impossibility of taxation will be recognised, whether by decision of the Federal Office of Finance, the Administrative Court or the courts. However, many executives may be less familiar with how they can sometimes reduce their tax bill by implementing a “cost-sharing agreement” between departments that deal with the internal transfer of intangible products or services. . .


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