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Impacts of SC Cosit 85/23 on corporate taxation
Federal Revenue Service determines that change of secondary activity does not imply change of branch for the purpose of compensation of tax net operating losses (NOLs).
Fine of 50% on tax compensation not approved is unconstitutional
Supreme Court decision allows the taxpayer to claim restitution of the amounts unduly paid in the last five years.
New Brazilian transfer pricing policy
Fundamentals of MP 1,152/22 and the arm's length principle
ICMS tax incentives can be extended for 10 years
PLP No. 79/2023 provides for extension of the term until 2042 and revoke the gradual reduction for tax incentives as of 2029
Collective applications for mandamus brought by associations
A decision by the STF reinforces the importance of previously evaluating the risks involved in the use of res judicata resulting from applications for mandamus of this nature.
The new Brazilian transfer pricing policy
The conversion of MP 1,152/22, the taxpayer's option in 2023, and businesses restructurings
Unconstitutionality of 50% fine on unapproved tax offsets
Supreme Court decision allows the taxpayer to claim restitution of the amounts unduly paid in the last five years
Trilogy: Carf outlook in 2022 and perspectives for 2023
In the last article of the series, we take stock of the judgments of the 3rd Panel of the CSRF.
Trilogy: Carf outlook in 2022 and perspectives for 2023
The main judgments of the 2nd Panel of the CSRF.
Carf's outlook in 2022 and prospects for 2023
Starting a series of three articles, we analyze the past year and take stock of the judgments of the 1st Panel of the CSRF.
Federal Government presents a new package of fiscal recovery measures
The package of measures, called "Zero Litigation", modifies the processing of administrative tax proceedings and establishes new models for settlements or installment plans.
Discount on AFRMM rates is revoked
Decree 11.374/23 recovers amounts of the Additional Freight for Renewal of the Merchant Navy in force until January 1st of this year.
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