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The STJ's understanding on suspension of protest and registration in Cadin in tax foreclosures guaranteed by performance bond or bank guarantee.
Illustrative image. Print of test with multiple choice question being marked by a pencil. In the lower left corner, yellow band with the words: "Carf Judgments column"
An analysis of Bill 2,384/23 and ADIs 6,399, 6,403, and 6,415.
Image of the planalto palace in Brasilia. In the lower left corner, yellow band with the words: Carf Judgments Column.
Text approved is the substitute of the rapporteur and will now be submitted to the analysis by the Senate.
Illustrative mockup of two tablets, one above the other, with images of the internal content of the e-book. In the upper right corner, descriptive strip in yellow and gray, with the name "e-book" written on it
In this e-book, we summarize what you need to know about the text of the Tax Reform to be considered by the Senate and how Machado Meyer can help you identify the impacts of possible changes for your business.
Business person stamp on the contract documents on the desk, the concept of contract confirmation or approval, the authority to authorize solicitation.
Text on transfer pricing rules now goes to the Senate for review.
Impacts of SC Cosit 85/23 on corporate taxation
Federal Revenue Service determines that change of secondary activity does not imply change of branch for the purpose of compensation of tax net operating losses (NOLs).
Fine of 50% on tax compensation not approved is unconstitutional
Supreme Court decision allows the taxpayer to claim restitution of the amounts unduly paid in the last five years.
New Brazilian transfer pricing policy
Fundamentals of MP 1,152/22 and the arm's length principle
ICMS tax incentives can be extended for 10 years
PLP No. 79/2023 provides for extension of the term until 2042 and revoke the gradual reduction for tax incentives as of 2029
Collective applications for mandamus brought by associations
A decision by the STF reinforces the importance of previously evaluating the risks involved in the use of res judicata resulting from applications for mandamus of this nature.
The new Brazilian transfer pricing policy
The conversion of MP 1,152/22, the taxpayer's option in 2023, and businesses restructurings
Unconstitutionality of 50% fine on unapproved tax offsets
Supreme Court decision allows the taxpayer to claim restitution of the amounts unduly paid in the last five years
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