Tagged with: Tax

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...

Normative Instruction No. 1,765/17, published on December 4 of last year, conditioned the receipt of offsetting statements for IPI credits, contribution to PIS, Cofins, and negative IRPJ or CSLL balances on prior confirmation of transmission of tax...

Abuses by the State and especially by the tax authorities to impose taxes without proper legal support are not uncommon. This routine fact, in addition to the excessive tax burden, the enormity of instrumental duties, and the extremely high...

This article discusses the possibility that taxpayers may obtain from the Public Treasury reimbursement of expenses incurred in contracting for a bank guarantee or insurance-guarantee offered in guarantee in tax executions as a requirement for...

Since the Federal Police launched Operation Zelotes in 2015, which unveiled corruption cases in the Administrative Tax Appeals Board (CARF), the body has undergone several institutional changes, such as a change in its directors, changes in...

A virtual financial asset very much in vogue, bitcoin is a bet by economists to cheapen transactions, especially those that occur in the international sphere. In general, financial intermediaries require remuneration for their participation, albeit...

Covenant No. 52/2017, recently issued by Confaz (National Finance Policy Council), followed the understanding of the Second Panel of the STJ (Superior Court of Justice) in the sense that the ICMS due under the withholding regime (ICMS-ST) is...

Decree No. 9,042, promulgated by the President of Brazil in early May, modified the rules for determining the reference price of oil and the basis for calculating royalties and special participations by adding provisions to Decree No. 2,705/1998....

Bitcoins have gained increasing prominence in the media. In March, the price of each unit surpassed the value of one ounce of gold for the first time. In addition, some online retailers have begun to accept bitcoin as a means of payment, which has...

A specific point of the Special Tax Regularization Program (PERT), instituted by Provisional Presidential Decree No. 783, of May 31, 2017 ("MP"), has been questioned by some companies and will in many cases be essential in reaching a decision on...

Tax

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

Errors in fact and offsetting statements for federal taxes

Changes in ISS introduced by Complementary Law No. 157/2016 cause legal uncertainty

Does the Public Treasury have to reimburse expenses with contracting for a judicial guarantee?

Number of CARF acts challenged in court grows

Income tax on payments in bitcoins

Controversies in the formation of the ICMS tax basis by tax substitution

Expectations for the regulations regarding new rules by ANP for calculating oil royalties

The taxation of bitcoins and other virtual currencies

MP 783/17: who is entitled to reduction in initiation fee from 20% to 7.5%

Who we are

CAREER

CAREER

LEGAL INTELLIGENCE CENTER

Privacy

Information Security

Integrity