Tagged with: Tax

The trilogy on the main topics analyzed in each of the three panels of the Superior Chamber of Tax Appeals (CSRF) of the Administrative Board of Tax Appeals (Carf) in 2022, we analyze in this article the cases decided by the 3rd Panel of the CSRF...

The Administrative Council of Tax Appeals (Carf) started 2023 with changes and the expectation that great challenges will be solved. The body is already under the leadership of a new chairman, Carlos Higino Ribeiro de Alencar, appointed on January...

Challenge and innovation were words that certainly represented the year 2022 for the Administrative Council of Tax Appeals (Carf). The first months of the year were marked by stoppage of the judgment sessions due to the adherence of part of the...

On January 12th of this year the federal government published Executive Order 1,160/23 and PGFN/RFB Joint Ordinance 1/23, which bring in a series of proposals for reducing the primary deficit. The package of measures, called "Zero Litigation",...

Decree 11,374/23, published on January 2nd of this year, revoked the Decree 11,321/22, of December 30, 2022, which had established a 50% discount for the rates of the Additional Freight for the Renewal of the Merchant Navy (AFRMM)...

Published on December 30, 2022, the Decree 11,322/22 reducedPis and Cofins rates levied on financial revenues from companies subject to the non-cumulative regime. The rates went from 0.65% and 4% to 0.33% and 2%, respectively. According to the...

Legal entities depend on a range of auxiliary activities to make their businesses viable, such as legal and information technology services, advertising, accounting, human resources, and others. To rationalize management, simplify procedures, and...

Constitutional Amendment 125, promulgated on July 14, 2022 (EC 125/22), introduced a new requirement for admiting the special appeal by the Superior Court of JUstice: demonstration of the relevance of the issues of federal law...

Executive Order 1,137, published on February 21 of this year, introduced a zero rate for withholding income tax (IRRF) on income paid to foreign investors. The goal is to attract foreign credit and encourage the issuance of private debt securities....

In recent years, incentives for electric and electrified vehicles, such as hybrids and plug-ins, have become increasingly common. This is because these vehicles are seen as a way to tackle the climate crisis by reducing greenhouse gas emissions....

The climate of antagonism experienced between the tax administration and the taxpayer favors the maintenance of a conflict relationship between the two parties. The construction of a new paradigm presupposes reducing the distrust of the taxpayer in...

The month of July in the Administrative Board of Tax Appeals (Carf) was marked by the long-awaited return of in-person judgment sessions, after more than two years of exclusively virtual sessions. The 1st Panel of the Superior Chamber of Tax...

After a little over two years without in-person sessions due to the pandemic, the Administrative Board of Tax Appeals (Carf) has resumed in-person work, now under new management, presided over by Board Member Carlos Henrique de Oliveira. The first...

Diana Piatti Lobo and André Essinger When talking about crediting PIS and Cofins on inputs, the normative and case law context is always the same: the legal references of articles 3, II, of laws 10,637/02 and 10,833/03 and the examination...

The deductibility of expenses with amortization of goodwill from the calculation basis of the Corporate Income Tax (IRPJ) and Social Contribution (CSLL)[1] is a topic that has long been discussed in the judgment sessions of the Administrative Board...

The 1st Panel of the Superior Court of Appeals (STJ) will define whether real estate payment transactions carried out by real estate investment funds (FII) can be taxed by the Real Estate Transfer Tax (ITBI) or are subject to tax immunity because...

Fernando Colucci and Alexia Costa Polloni The problem of gender inequality in taxation has gained greater visibility in the legal universe. There are several forms of taxation that mainly affect women. In early June, the Federal Supreme...

It is a fundamental guideline of the National Tax Code that taxes are not intended to punish any unlawful act: "Art. 3º Tributo is any payment of the compulsory pecuniary, in currency or the value of which can be expressed therein, which does not...

Hiring bonuses, also called sign-on bonuses, or in the sports arena, key money, is an amount that can be paid when hiring new professionals. The purpose of this payment is to attract highly qualified and already positioned professionals,...

The Federal Supreme Court (STF) began, on May 6 of this year, in a virtual plenary session, the long-awaited judgment of two extraordinary appeals with general repercussion concerning the limits of the temporal effects of res judicata in tax...

Tax

Trilogy: Carf outlook in 2022 and perspectives for 2023

Trilogy: Carf outlook in 2022 and perspectives for 2023

Carf's outlook in 2022 and prospects for 2023

Federal Government presents a new package of fiscal recovery measures

Discount on AFRMM rates is revoked

Reduction os PIS and Cofins rates on financial revenues is revoked

Carf's understanding on taxation of cost sharing

The requirement of the relevance of the special appeal

Main changes implemented by MP 1,137

Taxation of electric vehicle recharging

The proposal of the Taxpayer's Defense Code

The return of Carf's in-person sessions

Carf regulates in-person and hybrid judgment sessions

PIS and Cofins credit on expenses with advertising, marketing, and publicity

Goodwill in the Carf

ITBI on payment of FII quotas by conveyance of assets

The unconstitutionality of the alimony taxation

Police power charges are not used to penalise

Is there a social security contribution on hiring bonuses?

STF begins judgment of topics 881 and 885

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