CSRF's position on the levying of PIS and Cofins on apportionment of shared services expenses creates legal uncertainty by diverging from the standard already established by the Federal Revenue Service of Brazil.
Introduced by EC 125/22, the new institute focuses on the importance of the role of the Superior Court of Justice in standardising the case law.
Zero income tax rate aims to attract foreign credit and encourage the issuance of private debt securities.
The tax scenario on the subject is still imprecise and points to the need for legislative changes that ensure greater legal certainty.
PLP 17/22 and international models of cooperative tax compliance
Impressions on the judgments of the 1st Panel of the Superior Chamber of Tax Appeals after more than two years of exclusively virtual sessions.
Ordinance that regulates the topic provides for the possibility of removing a case from the agenda for a session in person to be judged in an exclusively virtual session.
Carf's case law indicates a restrictive interpretation on the topic, but an analysis by the highest level of appeal of the body may reverse this position.
A brief analysis of the case law of the Administrative Board of Tax Appeals over the years.
Superior Court of Appeals discusses the possibility of collecting the tax in transactions carried out by a real estate investment fund.
Supreme Court decision in direct action of unconstitutionality contributes to reduce gender inequality.
Recent decision of the Supreme Court on collection of the fee contradicts position taken earlier and creates doubts.
Recent Carf precedents reinforce arguments against discounting the amount.
Justices discuss the limits of res judicata in tax matters.
Position of the Court's 2nd Panel consolidates case law on the topic.
