- There is no option for affiliated entities to form a fiscal unity to avoid ABB on intercompany transactions
- Cost sharing agreements can be used to avoid ABB-taxation on intercompany transactions
- A cost sharing agreement is a legal agreement where costs are shared based on utilization of services
- The entity incurring the costs passes on the exact costs to other group entities
- The agreement and allocation key must be in place before the year-end.
Source: hbnlawtax.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
