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Cost Sharing and the Incidence of IBS and CBS

Complementary Law No. 214/2025 expanded the scope of IBS and CBS to cover onerous transactions based on economic substance, even in the absence of profit. In the context of cost sharing, the key issue is distinguishing pure reimbursement (payments made on behalf of and in the name of third parties, excluded from the taxable base) from the allocation of a company’s own costs, which may be characterized as the provision of intra-group services and, therefore, subject to taxation. Proper qualification and documentation will be essential to mitigate risks under the new regime.

IBSCBSTax ReformConsumption TaxationPure ReimbursementNon-Onerous TransactionTaxable BaseTax NeutralityCorporate Governance

Tax PMO: Project Management for Implementing the Tax Reform

Learn how the Tax PMO integrates project management and tax expertise to organize the implementation of the Tax Reform with governance and efficiency

Tax ReformTax ConsultancyProject ManagementPMOTax GovernanceTax Reform ImplementationPMO for Tax ReformImplementation of Tax Reform in CompaniesTax Project ManagementGovernance in Tax ReformImpacts of Tax Reform on CompaniesHow to Structure Tax Reform ProjectsConsultative Support in Tax ReformIntegration Between Tax and PMOIntegrated Management of Departments for Tax ReformIBS and CBS Adaptation ProjectMethodology for Tax Reform ImplementationConsultancy for Compliance with the New Tax SystemHow to Organize Internal Departments for Tax ReformTax ComplianceTax TransformationERP and Tax ReformInterdepartmental ManagementIndirect TaxesCorporate Governance