There are, of course, important exceptions to this rule, which include tax-exempt property rents, certain personnel costs and certain payments which, in certain circumstances, are not subject to VAT. I have spoken in more detail about these and a few other problems. It can be concluded that federal revenues do not have a clear directive against the non-taxation of transfers abroad when it comes to a cost-sharing agreement. In this context, it is worthwhile, for example, to respond to the request for an advance ruling No. 21 – General Tax Coordination Office in Brazil (COSIT) 2015, which distinguishes between the mere reimbursement and the actual provision of services for information purposes under an ancillary obligation called Siscoserv: a cost-sharing agreement is concluded when participants with common interests are exposed to costs for the realisation of the assets and rights of one of the companies in the group which they make available to the other undertakings, in accordance with justified distribution criteria. A contribution to the costs would be, taking into account the fruits, a means of reimbursing the entity holding the right or asset. It is also possible that the parent company provides a VAT-exempt service, although the costs are calculated by the distribution of standard costs. This is quite unusual, but it can occur when the activity is active in the financial services sector or in another exempt sector of activity. A good example would be the cost of the services of an independent financial adviser, calculated by reference to a share of staff costs plus office overhead costs. Some intercompany services need to be treated separately because they have a higher value. • Alternatively, the expense charge is simply a mechanism for calculating the costs of other services provided by the parent company to the subsidiary. A typical situation would be that there is a service management contract in which the parent company provides services defined by such an agreement – for example, consulting services, management services or services of certain employees – and the costs are based on part of the costs incurred by the parent company. `In view of the foregoing, in a contract for the apportionment of costs and expenses signed between undertakings of the same economic group in which residents and non-residents of the country participate, the activities made available to the resident legal person by a non-resident legal person must be registered with Siscoserv where the activity in question is provided for by NBS.
It is a transaction which includes an operation which entails a change in the own funds of the legal person, provided that the repayment offered in return for the activity provided represents a charge which necessarily involves a change in own funds. . . .