The Resource Cost sharing agreements and transfer pricing : tax treatment in Brazil

Cost sharing agreements and transfer pricing : tax treatment in Brazil

Label
Cost sharing agreements and transfer pricing : tax treatment in Brazil
Title
Cost sharing agreements and transfer pricing : tax treatment in Brazil
Creator
Subject
Language
eng
Summary
Brazilian tax legislation has undergone major modifications year after year, with significant improvements. National legislation now includes criteria that have been used for years in more developed countries. These transformations prompted an examination into what was already available in the Brazilian legislation, offering a more appropriate interpretation of existing legal provisions. Cost and expense sharing agreements are executed between or among companies with the purpose of sharing/allocating costs or expenses that one of them incurs with/to the others, as these costs or expenses eventually benefit all companies involved in the production of goods, services, or rights. The purpose of these agreements is to accurately determine the manner and extent that the latter companies must collaborate or take part in the costs and expenses that the former incurred, for the interest of the others. This article analyzes whether these agreements fall within the definition of service agreements and whether Brazilian transfer pricing rules should apply to remittances that Brazilian companies pay as reimbursement of expenses
Citation source
In: Journal of international taxation. - New York. - Vol. 24 (2013),
http://library.link/vocab/creatorName
  • Galhardo, L. Rosanova
  • Pereira, V. Pimenta Seixas
Geographic coverage
Latin America
Language note
English
http://library.link/vocab/subjectName
  • corporate income tax
  • cost sharing arrangement
  • services
  • transfer pricing
Label
Cost sharing agreements and transfer pricing : tax treatment in Brazil
Instantiates
Publication
Label
Cost sharing agreements and transfer pricing : tax treatment in Brazil
Publication

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