In assessing contributions, the OECD distinguishes between low-value activity and other CCAs. In cases where activities within a CCA are of low value (definition 7.44 of oecd guidelines for 2017), the OECD notes, for practical reasons, that contributions to the cost of acquisition can be assessed since, in such cases, the value of services is close to the respective costs. As a result, a simple low CCA value acquisition activity is treated in a manner almost identical to a CCA administrative activity according to the OECD concept and according to the concept of the (former) German tax authorities. In addition to these criteria, the RFB confirmed that each CCA is an official written document indicating the total cost incurred so as to assess the proportionality of the contributions and benefits of each company in the group. Given the strict requirements of the RFB for CCA validity and deductibility for the purposes of the YPI and CSLL. Cost contribution agreements concluded by a Brazilian party should be carefully developed and reviewed by a Brazilian lawyer before being concluded. ”A CCA is a contractual agreement between companies to share contributions and risks related to the development, production or acquisition of intangible assets, tangible assets or services, on the basis that these intangible assets, tangible assets or services should bring benefits to each company of each participant.” A cost-contribution agreement (also known as a ”cost-sharing agreement”) is a contract that allows companies in the same group to share contributions to the development of new products, services or intellectual property rights or to the operation of different companies that make up the group. In order for the costs and expenses related to corporation tax (”YPI”) and the social contribution to be deductible from net income (”CSLL”), the costs and expenses must be: in addition, the RFB follows the position outlined in the guidelines for companies that provide only services but do not receive participation in the outcome of the cost-sharing agreement – in these cases , the service provider must be compensated for the benefits on the basis of the length of the arms which does not have the effect of the cost-sharing agreement. The RFB has also adopted guidelines on the classification of cost-sharing agreements into two types: development CCAs and services CCAs.