Tagged with: Tax

What is the time of taxation, for the purposes of Corporate Income Tax (IRPJ) and the Social Contribution on Net Income (CSLL), of the tax credit recognized in court and subject to compensation? Answer to Advance Ruling Request183/21, published at...

The 1st Section of the Superior Court of Justice (STJ) recently ended a debate that had lasted for more than 20 years in the courts. In judging the embargoes of divergence in the Special Appeal (EREsp) 1.213.143/RS, the 1st Section recognized the...

Enacted by CAMEX Executive Management Committee (Gecex) at the end of last year, Resolution n. 291/21 extended the term of the Ex-tariffs listed in Section 1st of that document to April 30, 2022. The same Resolution authorized the Secretariat for...

The constitutionality control of all the norms introduced in the system of brazilian positive law is ultimately conferred on the Supreme Federal Court (STF).[1] The compatibility of the norms with the most appropriate interpretation of the Federal...

The covid-19 pandemic intensified the adoption of remote work, through which the employee performs his duties without physically attending the company. From the perspective of social security contributions, the place where the employee performs...

One of the greatest virtues of the Judiciary is to pacify social relations through the jurisprudence it creates on the various themes that are submitted to it. It happens that, in Brazil, even today, attempts to resurrect issues already faced by...

Historically, case law has tended to reduce the influence of tax liabilities on judicial reorganizations, with the recurrent relaxation of the rules on mandatory proof of good tax standing for companies petitioning for judicial reorganization...

The Superior Court of Appeals (STJ) decided, in 2018, Repetitive Appeal (REsp) 1.221.170/PR, which dealt with appropriation of PIS and Cofins credits based on the concept of inputs. At the time, the STJ gave the legal interpretation to the...

In 2018, the Superior Court of Appeals (STJ) ruled out the restrictive concept of input material, according to which the expense with input material should be directly integrated into the formation process of the end product or provision of service...

Since the general repercussion became a requirement for admission of extraordinary appeals in the Supreme Court (STF), this type of appeal has been paving the way for questions of great national interest to reach the Court and affect a significant...

With the publication of Decrees Nos. 47,767/21 and 47,768/21 on September 21, the State of Rio de Janeiro regulated, respectively, Laws Nos. 9,214/21 and 9,289/21, which define special tax treatment for thermoelectric projects in its territory....

Leonardo Martins and João Victor Sadocci With the publication of Law No. 6,999 on July 14 of this year, the City of Rio de Janeiro instituted tax benefits for the building works framed in the Reviver Centro Program, created to promote the urban,...

The recent Answer to Consultation (SC Cosit) no. 99, of June 21 of this year, dealt with the imposition of Withholding Income Tax (IRRF) in the conversion of foreign investment in the Brazilian financial and capital markets via portfolio, pursuant...

Leonardo Alfradique Martins and André Araújo de Andrade Budget funds are a classic way to individualize and link revenues for a given purpose. Its use dates back to the time of colonial Brazil and gained more traction with the increasing...

Since the promulgation of the Federal Constitution of 1988 (CF/88), a widely discussed topic has been the selectivity applicable to the Tax on Circulation of Goods and Services (ICMS). Amid wide-ranging debates regarding tax reform and changes in...

"The ignorant affirm, the wise doubt, the sensible reflect", said the Greek philosopher Aristotle, stating that it fits well to the context of recent tax disputes reviewed by the Federal Supreme Court (STF) and deserves to be remembered because of...

Leonardo Martins, Carolina Stephanie Borges de Amorim and Pedro de Lima Souza Alves The Federal Supreme Court (STF) recently reaffirmed its position in relation to the unconstitutionality of the institution of a fire safety fee by the...

Due to the severe and persistent financial difficulties faced by the Economy of Rio de Janeiro in 2017, the state of Rio de Janeiro signed the Fiscal Recovery Regime (RRF) with the federal government. Approved by Complementary Law No. 159/17, the...

The Ministry of Economy presented last friday (25) a proposal of tax reform, including certain rules regarding the taxation of individuals, legal entities and financial investments. We highlight above the main points of the Bill of Law presented to...

As a result of Law No. 13,988/20, which regulates the tax transaction provided for in the National Tax Code (art. 171)[1], the Federal Revenue Service of Brazil (RFB) and the Attorney General's Office of the National Treasury (PGFN) signed, on...

Tax

Consultation Solution 183/21 and the timing of taxation by IRPJ and CSLL of judicially recognized illiquid claims

STJ standardizes jurisprudence on the right to maintain Excise Tax (IPI) credit in non-taxed outflows

Deadline to request extension of Ex-tariff ends this month

Supervening constitutionality: the position of the Supreme Court

The incidence of social security contributions and transnational work

The re-establishment of the already rejected TFPG by the state of Rio de Janeiro. Is it?

The current situation of the tax authorities and judicial reorganizations

PIS and Cofins credits in the context of the pandemic

STJ will examine the reach of a repetitive theory regarding the concept of input material in the generation of a PIS and Cofins credit

Extralegal factors can be considered for modulation the effects of supreme court decisions?

Rio de Janeiro regulates special tax treatment for thermoelectric power generation projects

Rio de Janeiro City Hall creates tax benefits for the Reviver Centro Program

Cosit 99/21 Answer to Consultation: IRRF is not due on capital gains earned in shares traded in the Brazilian stock exchange in the conversion of foreign investment, via portfolio, to foreign direct investment

Abuse in the creation of budget funds by state entities

Application of the selectivity criterion according to the essentiality of the product or service for the ICMS

ADC 49: repercussion on the ICMS in the transfer of goods between establishments of the same holder

Supreme Court considers unconstitutional the collection of fire safety fee

The necessary suspension of the collection of the deposit to the Transitional Budget Fund while the Fiscal Recovery Regime of the state of Rio de Janeiro is suspended in court

2nd phase of the Brazilian Tax Reform | Income Taxation

New form of tax transaction involving PLR

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