“Given the above, the activities made available to the resident corporation by a non-resident corporation must be registered with Siscoserv in a cost and expense allocation contract signed between companies of the same economic group involving residents and non-residents of the country, where the activity in question is provided for in the NBS. This is a transaction involving a transaction that results in a change in the equity of the corporation, provided that the repayment offered in return for the activity is a charge that necessarily involves a change in equity. Under the cost-cutting agreement, there is a subcontracting of certain services by the centralizing corporation for the benefit of other members, the resulting mandatory relationship being the character of an authentic service delivery, the third party mandated being the service provider and the legal persons of the group as policyholders who actually benefit from the services. Where the supplier is established or resides abroad, the registration of information about Siscoserv is mandatory to be carried out by an insurance taker based in Brazil. If the allocation between the parties is to be done solely in compensation for costs, it is not possible to impose taxes such as: despite the controversy over the imposition of transfers, the deductibility of expenses and costs – IRPJ / CSLL – and the credit – PIS / COFINS – has a favourable position for taxpayers, following the response to the tax request No. 94 COSIT of March 25, 2019, in which it is stated that federal revenues have, however, given several responses stating that a tax should be levied on these transfers (Soluéo de Consulta Disit/SRRF09 no 9026 of August 29, 2018). However, it appears that this interpretation is more related to the specific case, as it theoretically meets the requirements of an effective cost-sharing agreement. As long as these conditions or requirements are met, the Confederation of Federal Receiving Services Authorities may therefore conclude that there is no taxation (IRPJ, CSLL, PIS and COFINS). It is also reasonable to conclude that the same reasoning prevents municipalities from raising the ISS.