Cost Sharing Group Agreement

the exemption only applies to member services (i.e. one or more members). Therefore, any service of the members to the independent group does not fall within the scope of Article 132(1)(f) of the VAT Directive. Under the EU VAT Directive (hereinafter referred to as `the VAT Directive`), the general principle is that all supplies of goods or services supplied by taxable persons for remuneration are taxed. There are, however, some exceptions to this general principle, under which certain supplies are exempt from VAT. One of the exemptions is provided for in Article 132(1)(f) of the VAT Directive, which deals with cost-sharing agreements. Under this section, the term “independent groups of persons” (IPC) was used instead of cost-sharing agreements. That provision exempts the supply of services by groups which carry out an activity exempt from VAT or for which they are not taxable persons in order to provide their members with the services directly necessary for the pursuit of that activity, where those groups require their members only to reimburse their share of the common costs exactly, provided that such an exemption cannot lead to distortions of competition. This exemption is presented more clearly below: Despite the controversy over the taxation of transfers, the deductibility of expenses and costs – IRPJ/ CSLL – and credits – PIS / COFINS – is favourable to taxpayers, according to the response to request for an advance ruling No 94 COSIT of 25 March 2019, which provides that the referring court has requested from the Court of Justice of the European Communities information on the concept of PGI under Article 132(1)(f) of the VAT Directive, on whether the exemption could be combined with a transfer price margin and whether the exemption could be used in a cross-border case. DNB Group consists of several companies active in the financial services sector. One of these units is DNB Banka (Latvia), a subsidiary of DNB NORD (Denmark), itself a subsidiary of DNB Bank (Norway). DNB NORD (Denmark) is also the parent company of DNB IT (Denmark). In this case, DNB Banka (Latvia) concluded contracts with DNB NORD (Denmark) and DNB IT (Denmark) for the provision of financial management and IT management services.

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