Tagged with: Tax

On March 15th, 2017, the Federal Supreme Court (STF) judged Extraordinary Appeal No. 574.706/PR (with recognized general repercussion), in which it was established that the ICMS is not included in the tax base for contributions to PIS and Cofins....

The Government of the State of Rio de Janeiro has enacted a new special program for the payment of tax debts and fines from the State Accounting Court, through Complementary Law 182/2018 (LC 182/2018), published last Friday (September 21)....

The Plenary Session of the Administrative Council of Tax Appeals met on Monday, September 3, to review 32 proposals for new precedents and to update and cancel certain precedents in force. As a result of the session, 21 new precedents were...

A topic has been provoking debates in the administrative tax sphere in the State of São Paulo: the drawing up of infraction notices and impositions of fines (AIIM), based on article 84-A of Law No. 6,374/89, to disregard acts and legal...

The 1st Panel of the Superior Court of Justice (STJ), in the judgment on Special Appeal No. 1.477.320, recognized the right to PIS and Cofins credits in relation to transportation in transactions to purchase vehicles from the manufacturer by the...

The Federal Supreme Court (STF) recognized the constitutionality of the Social Contribution on Net Income (CSLL) on July 1, 1992, by means of the decision rendered in RE No. 138.284/CE. This position was confirmed in a consolidated manner in ADI...

State Law No. 7,988/18 - RJ, published on June 15, revoked Article 75-A of Law No. 2,657/96 (the ICMS Law) in order to establish new rules regarding the procedures that the tax auditor of the Rio de Janeiro state revenue office must observe in...

CAT Ordinance No. 59, published on July 6th by the State of São Paulo, governs the activities of logistics operators that store goods belonging to third-party ICMS taxpayers. Among the relevant points, we highlight: Concept of logistics operator...

ICMS Convention No. 51/18, published on July 5th, amended ICMS Convention No. 190/17, which governs, under the terms authorized in Complementary Law No. 160/2017, the remittance of tax credits arising from exemptions, incentives, and tax or...

Taxpayers will no longer be able to offset federal tax credits with debts related to the monthly collection due to IRPJ and CSLL estimates, according to Law No. 13,670/2018, published on May 30 (inclusion of item IX in paragraph 3, article 74, of...

Investment funds have had a prominent place in the Brazilian financial market because they enable the gathering and consolidation of assets from different investors into a single investment channel. Unlike the general rule applicable to legal...

Today, the São Paulo State Revenue Service published two important normative acts related to the ICMS-ST: (i) CAT Notice No. 06/2018, which "clarifies ICMS reimbursement due to tax substitution, in view of the decisions rendered by the Federal...

Brazil has for years been witnessing an intense debate regarding the constitutional jurisdiction to tax the most varied of legal deals involving digital assets, more precisely software, whether it is the ICMS, ISS, or neither of the two. Law No....

The 2nd Panel of the Superior Court of Justice (“STJ”) granted a taxpayer’s appeal to recognize that the ICMS cannot be included in the calculation basis of the Social Security Contribution on Gross Revenue (CPRB). The decision was issued in...

The right to a tax offset recommends reflection on the rules issued by the legislator that shape such offsets. Among the rules, special mention should be made of section 170-A of the National Tax Code (CTN), introduced by Complementary Law No....

On April 7, 2018, the State of São Paulo published Complementary Law No. 1,320, of April 6, 2018 ("LC No. 1,320/2018"), resulting from Bill No. 25/2017, which establishes the Program for Stimulating Tax Compliance, “Compliance Program", defining...

Ordinance CAT No. 24/2018, enacted on March 23, governed, among other issues, transactions with digital goods and merchandise traded through electronic data transfer. The objective was to regulate the changes implemented by Convention 106, of...

Companies were surprised last September with the enactment of ICMS Convention 106, which aims to regulate the procedures for collection of ICMS applied to transactions with digital goods and merchandise, traded through electronic data transfer, and...

Although it is part of the Base Erosion and Profit Shifting (BEPS) Project to counteract multinationals’ tax planning that uses the loopholes of the international system to reduce their overall tax burden, Brazil has not signed the Multilateral...

Last year was special for the Administrative Council of Tax Appeals (Carf). The period began with heated discussions (and many lawsuits) questioning the productivity bonus of tax auditors [1] and ended with the joining of the representatives of the...

Tax

ICMS excluded from the tax base of contributions to PIS and COFINS - position of the RFB

State of Rio de Janeiro institutes a new special program for the payment of tax debts and fines of the state accounting office

CARF plenary session approves 21 new precedents

Does the São Paulo State tax authority have jurisdiction to disregard acts and legal transactions in order to create an ICMS tax debt?

STJ recognizes right to PIS and COFINS credits arising from expenses with transportation of vehicles from the manufacturer to the dealer's headquarters

CSLL: possibility of collection even when there is a final and unappealable decision to the contrary generates legal uncertainty

Enactment of Law No. 7,988/18 RJ - Disregard of legal acts and deals by the Rio de Janeiro State Revenue Office

Main points of CAT Ordinance No. 59/18

Changes brought in by ICMS Convention No. 51/18

Law re-establishes prohibition on offsetting IRPJ and CSLL

Investment funds targeted by the Brazilian Federal Revenue Service

Relevant changes in the ICMS-ST for the State of São Paulo

ISS vs. ICMS in taxing streaming and accessing software in the cloud

STJ reaffirms that ICMS is not included in the calculation basis for the CPRB

Carf's recent decision has impacts on the systematic interpretation of section 170-A of the CTN in the light of institutes of general repercussion and repetitive appeals

COMPLEMENTARY LAW NO. 1,320/2018

Ordinance CAT 24 Published

Unconstitutionality of ICMS Convention 106/2017

Brazil's responses to BEPS - implementation through the double taxation agreement with Argentina

Carf’s balance sheet in the year 2017

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