Tagged with: Tax

Beginning the series of articles on the changes implemented by Executive Order No. 905, published on Tuesday, November 12, we review below changes in the rules for creating and paying a Profit Sharing Plan (PLR). Granted by companies to their...

A growing number of Brazilians have opted to live abroad in recent years. The reasons for this choice are manifold: while in previous decades they were linked to employability and formation of equity, today they are more related to quality of life,...

The penalty of forfeiture of property is one of the most severe and extreme penalties contained in Brazilian law. Despite its confiscatory nature, the Federal Supreme Court (STF) has already abstractly recognized its validity and compliance with...

Continuing the series of articles on the changes implemented by Executive Order No. 905, published last Tuesday, we review below the changes regarding the payment of premiums by companies to their employees. As already discussed in this article,...

Executive Order (MP) No. 899/19, already known as the Legal Taxpayer's Executive Order, was published on October 17 of this year with the purpose of reducing tax litigation and recovering debts classified as irrecoverable or difficult to recover....

Since the STF settled the theory that the ICMS tax is not included in the taxable base for the levy of the PIS and Cofins, in the judgment of Extraordinary Appeal (RE) No. 574,706, many taxpayers had a definitive resolution in their individual...

One issue that is the subject of frequent debate in the administrative courts with jurisdiction to decide issues raised against infraction notices is the possibility for the administrative authority, after drawing up the infraction notice, to...

With their publication in the Official Federal Gazette last September 10, 33 precedents approved at the en banc meeting of the Superior Chamber of Tax Appeals (CSRF) of the Administrative Council for Tax Appeals (Carf), held in early September,...

With the main objective of combating delinquent debtors and strengthening the collection of outstanding debt within the federal tax administration, the Ministry of Economy presented to the Chamber of Deputies, in March, Bill No. 1,646/19. Some...

There are two main forms of defense in tax foreclosures: the pre-foreclosure exception and the motion to stay enforcement. The first is presented in the record, without the need to guarantee the tax debt under debate, that is to say, it is...

For some time the classification of ICMS tax incentives as an investment subsidy has long been debated in the tax courts. The relevance of this discussion stems from the possibility of excluding income from investment subsidies from the IRPJ...

The natural gas market is gaining more and more relevance in Brazil as a way to diversify the country's energy sources. To foster the development of the sector, changes in legislation and regulations have been discussed, especially since 2016, when...

Normative Instruction No. 1,888/2019 (IN 1,888), which establishes and disciplines the provision of information related to cryptoasset transactions, shows the concern of the Brazilian Federal Revenue Service (RFB) with providing transparency in...

Law No. 13,655/2018, published in early 2018, included new general principles in the Law of Introduction to the Norms of Brazilian Law - Lindb (Decree-Law No. 4,657/1942) and since then, much has been said about the applicability of the changes in...

At the end of last year, Justice Dias Toffoli released for judgment Extraordinary Appeal No. 1.063.187, Topic of general repercussion No. 962, which litigates the levying of Corporate Income Tax (IRPJ) and the Social Contribution on Net Income...

The State of Rio de Janeiro Finance Department (Sefaz-RJ) enacted the Resolution Sefaz No. 24, on March 27, 2019, allowing taxpayers to request or to rectify the Digital Tax Bookkeeping, the so-called EFD, without the previous payment of the Charge...

I. Introduction In a recent decision handed down in Special Appeal No. 1.733.560/SC, the Second Panel of the Superior Court of Justice (STJ) recognized the non-applicability of the Corporate Income Tax (IRPJ), Social Contribution on Net...

At the end of 2017, Justice Regina Helena Costa, of the First Panel of the Superior Court of Justice (STJ), admitted an appeal against a divergent decision filed by a taxpayer (EAREsp No. 1.078.194/RJ) against an appellate decision that established...

Launched in October of last year as a very positive initiative by the Federal Revenue Service of Brazil (RFB) to guide taxpayers, in addition to avoiding default and potential litigation, the draft ordinance establishing a federal program to...

The system of precedents established by the Brazilian Procedure Code published in 2015 (CPC/2015) is based on the premise that trials of given instruments will have a binding effect on the Judiciary and that, solely for this reason, decisions that...

Tax

MP 905 fights understanding adopted by CSRF in issues relating to payment of PLR

Leaving Brazil: Procedures and Risks to Observe

TRF-2 sets aside penalty of forfeiture in case of detour during customs transit

MP 905/2019 changes requirements for payment of premiums

Legal Taxpayer Executive Order: types of settlements allowed between debtors and the government

Exclusion of the ICMS from the PIS/Cofins basis: controversy over when to tax credits recognized in court

Modification of the legal criterion on the Infraction Notice in the CARF’s case law

The new precedents of the Administrative Council for Tax Appeals

Bill 1,646/19: Fight against delinquent debtors and collection of outstanding debt

Settlement of letters of guarantee or performance bonds in tax foreclosures

Conditions for non-taxation of revenues from ICMS incentives: an analysis according to the precedents of the STJ

Tax barriers for the natural gas industry

Information on transactions with cryptoassets to the Brazilian Federal Revenue Service: costs, scope, and possible impacts for users and operators

Repercussions of the changes in the Law of Introduction to the Norms of Brazilian Law in the Carf

IRPJ and CSLL not levied on amounts received through the application of the Selic rate

Rio de Janeiro State dismisses payment of charge to rectify the Digital Tax Bookkeeping (EFD)

Tax aspects of real estate swap arrangement: analysis of the STJ’s decision in Special Appeal No. 1.733.560/SC

First Section of the STJ may define whether or not the ICMS-ST has its own taxable base

Vulnerable points in the federal program to stimulate tax compliance

Binding precedents pursuant to the Brazilian Procedure Code and the usefulness of the average vote

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