Brazil has published Private Ruling 94/2019 of 25 March 2019 in the Official Gazette, which clarifies the tax treatment of administrative expense under a cost-sharing agreement. The Circular notes that the control of expenses under a cost-sharing agreement in relation to centralized administrative support departments may be concentrated in a single company and later apportioned between group companies. In this respect, for the administrative expenses to be deductible for the purpose of corpo…