Accordingly, this participant must receive a subcontracted payment from each controlled participant whose share in the intangible development costs is less than the time, in accordance with the provisions of §1.482-1 and 1.482-4 to 1.482-6. Before that, cost-sharing agreements were widespread among multinationals. Often, a company of the same economic group, headquartered abroad, can be the one that centralizes these support activities in collaboration with the company established in Brazil. It is precisely in this case that the above-mentioned CARF decision is relevant. (ii) In order to determine whether a cost allocation for the first year, approved under paragraphs 1.482 to 7(a)(2), is appropriate, the District Director shall compare the shares of usp and FS in the intangible development costs for that year with their reasonably expected benefit shares. .