In Brazil, it can be said that reimbursements under cost-sharing agreements made by domestic companies are not taxed under the IRPJ/CSLL, PIS/COFINS and ISS, provided certain conditions are met and these expenses are deductible or tax credits are available. (3) Vote, see 1.482-1. A qualified cost-sharing agreement yields results with an arm length result in the sense of . 1.482-1 (b) (1) if, and only if, if the share of each controlled participant in the costs (as defined in paragraph (d) of this section) of intangible development under the eligible cost-sharing agreement corresponds to its share of reasonably expected benefits due to such a development (in accordance with paragraph (2) of this section) and if all other requirements in this section are met. (4) In a document that is carried out at the same time as the formation (and each revision) of the cost-sharing agreement and which includes – 2) the shares negotiated by the public. As is used in this paragraph (d) (2) (iii) (B), publicly traded shares are shares that are periodically traded on a U.S.-based securities market and issued by a company whose financial statements are prepared in accordance with accounting standards generally accepted by the United States for the taxable year. Although the nature of these contracts is discussed, it is possible to identify at least three distinctive characteristics between the parties based on the structured structure: (i) cost-sharing agreement; (ii) intragroup service agreement; and (iii) cost-contribution agreement. If the allocation between the parties is intended only to compensate for costs, it is not possible to impose taxes such as: (l) transitional rule. A cost-sharing agreement is considered a qualified cost-sharing agreement within the meaning of this section; if the agreement was a good faith cost-sharing agreement before 1 January 1996, in accordance with the provisions of p. 1.482 to 7T (as included in edition 26 CFR, part one, revised from April 1, 1995), only if the agreement is amended, if necessary, to comply with the provisions of this section until December 31, 1996. Under such conditions, there are still doubts and controversies. However, if there is an effective cost-sharing agreement with the respective controls, we believe that, whether by decision of the Federal Finance Tribunal, the administration or the court, there will be the impossibility of taxation.
(2) provide a method of calculating the share of each controlled participant in intangible development costs on the basis of factors reasonably likely to reflect that participant`s share of the expected benefits; (3) Generally accepted accounting principles. For the purposes of this paragraph, (d) (2) (iii) (B) a financial statement based on a comprehensive set of generally accepted accounting standards is considered to be a generally accepted accounting repository established in accordance with generally accepted U.S. accounting principles, provided that either – (ii) or, in the absence of coordination between these other accounting principles and the generally accepted accounting principles of the United States, which reflect the fair value of the stock options concerned. other accounting principles require that the fair value of the affected stock options be recorded as a charge on the income of the audited financial statements or in the footnotes of those financial statements.