Tagged with: Tax

The Labor Reform (Law 13.467/17) changed, among other points, rules on the breaks for rest and feeding during the working day. Before the Labor Reform, in force since November 11, 2017, there were discussions about whether the payment resulting...

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The discussion on the (non) taxation of revenues arising from investment subsidies granted by Brazilian states to taxpayers has recently taken on new contours with the judgment of Theme 1,182 by the Superior Court of Justice (STJ). The...

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The State Treasury Office of the State of São Paulo published, on July 31, SRE Ordinance 51/23, which repeals CAT Ordinance 115/14, which may represent a setback in relation to the measures already in place for the exemption from the issuing of...

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In the judgment of the Direct Action for Constitutionality[1] 49 (ADC 49), the Supreme Constitutional Court (STF) ruled that the levy of ICMS on transfers between establishments of the same entity is unconstitutional. According to the judgment,...

Brazil introduced Provisional Measure No. 1152 on December 29, 2022, updating its transfer pricing rules to align more closely with international standards, especially as the country evaluates its integration with the OECD. The new rules, which...

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Section 1, paragraph 1, of Law 9,873/99, establishes a limitation "in the administrative proceeding, paralyzed for more than three years, pending judgment or order”, determining its ex officio cancelation. In the scope of tax law, reaching the...

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The Supreme Court concluded, on June 12, the trial of motion for clarification filed in the extraordinary appeal 400,479 (RE 400,479), whose objective was to define the scope of the concept of billing for companies in the insurance sector in the...

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In recent years, although the Superior Court of Justice (STJ) has established theories on the use of performance bonds or bank guarantee as security in tax litigation, taxpayers still face legal uncertainty regarding the effects of presenting...

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"

One of the first measures adopted by the new government, in January of this year, was the promulgation of Executive Order 1,160/23, which reinstated the casting vote as a tiebreaker criterion in judgments by the Administrative Council for Tax...

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The House of Representatives approved, in plenary session on July 7, the Bill of Law 2.384/23, which resumes the casting vote at the Administrative Tax Court (Carf). The approved text is the replacement suggested by the rapporteur, Mr Beto Pereira...

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The Tax Reform was elected as a priority to unlock Brazil's economic growth and improve the business environment. The proposal already approved in the House of Representatives seeks to unify the main consumption taxes and create a simpler and...

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The House of Representatives approved, on March 30, Executive Order 1,152/22, which amends the legislation of the Corporate Income Tax (IRPJ) and the Social Contribution on Net Profits (CSLL) to provide for transfer pricing rules. The approval...

The Federal Revenue Service of Brazil (RFB), through its General Coordination of Taxation (Cosit), published, on April 12, the Private Letter Ruling Cosit 85/23 (SC Cosit 85/23), to determine the limits of the restriction on the use of tax Net...

The Federal Supreme Court (STF) concluded, on March 17, the judgment of Extraordinary Appeal 796.939 / RS (Theme 736 of the General Repercussion) in the virtual plenary. At the time, the Court analyzed the constitutionality of the isolated fine of...

The Federal Constitution instituted the Financial Compensation for Mineral Exploitation (CFEM) – more commonly known as "mining royalties" – as a consideration for the economic use of mineral resources (Union assets) to be collected by the...

The Chamber of Deputies approved, on March 30, the conversion project of Provisional Presidential Decree 1,152/22 (“MP 1,152/22”), which introduced the new Brazilian transfer pricing policy. Among the innovations in the conversion process, the...

The Complementary Law Project (PLP) No. 79/2023, presented in the Federal Senate on March 30, 2023, allows the extension of the term of the tax and financial-tax incentives of ICMS (Tax on the Circulation of Goods and Services) reinstituted under...

The filing of an application for mandamus by associations has become increasingly common in the area of tax law. The existence of a favorable final and unappealable decision, capable of benefiting all members regardless of their date of membership,...

Provisional Presidential Decree 1,152 (“MP 1,152/22”), published on December 28, 2022, introduced the new Brazilian transfer pricing policy, in line with the guidelines of the Organization for Economic Cooperation and Development (OECD) and the...

The Federal Supreme Court (STF) concluded, on March 17, the judgment of Extraordinary Appeal 796,939/RS (Theme 736 of the General Repercussion) in the virtual plenary. At the time, the Court analyzed the constitutionality of the isolated fine of...

Tax

Labor Reform and taxation

Clash over taxation of investment subsidies

New norm for exemption from Tax Infraction Notices in SP

ICMS on the transfer of products between establishments of the same entity

Ebook: MP 1152 – New transfer pricing rules

Statute of limitations of customs charges

Calculation basis of PIS and Cofins for the insurance sector

Use of judicial performance bond and bank guarantee

New developments on the casting vote with the Carf

House of Representatives approves resumption of the casting vote at Carf

Ebook: Tax Reform on consumption

MP 1,152/22 is approved by the House of Representatives

Impacts of SC Cosit 85/23 on corporate taxation

Fine of 50% on tax compensation not approved is unconstitutional

The CFEM and the collection of PIS and Cofins

New Brazilian transfer pricing policy

ICMS tax incentives can be extended for 10 years

Collective applications for mandamus brought by associations

The new Brazilian transfer pricing policy

Unconstitutionality of 50% fine on unapproved tax offsets

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