Brazil has published Private Ruling 94/2019 of 25 March 2019 in the Official Gazette, which clarifies the tax treatment of administrative expense under a cost-sharing agreement. The Circular notes that the control of expenses under a cost-sharing agreement in relation to centralized administrative support departments may be concentrated in a single company and later apportioned between group companies. In this respect, for the administrative expenses to be deductible for the purpose of corporate tax and social contribution on profits (CSLL), it is required that the expenses:
Further, all companies must appropriate as an expense only the portion allocated to them, the centralized company must account for the installments to be reimbursed as credits, and all records related to the apportionment of administrative expenses must be maintained.
We’re here to answer any questions you have about the Orbitax products and services.
We’re committed to providing high value, low cost tax research and management solutions.
Our Twitter account is where you can find latest information, news updates, offers and lots more.