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Brazil Clarifies Deduction of Administrative Expenses Under a Cost-Sharing Agreement

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:

  • correspond to normal, usual, and necessary costs and expenses, duly evidenced and paid;
  • are calculated based on reasonable and objective apportionment criteria previously agreed to and formalized by an instrument signed between the parties; and
  • correspond to the effective expenditure of each company and to the overall price paid for the goods and services.

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.

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