Tagged with: Tax

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...

By unanimous decision, the 2nd Panel of the Superior Court of Appeals (STJ) recognized the illegality of the early revocation of the tax incentive provided for in Law 11,196/05, known as the Asset Law. Through the Digital Inclusion Program, the law...

Can a normative instruction alter the calculation methodology prescribed by law for determining the transfer price in import and export operations involving goods, services, or rights? Must the taxpayer calculate the transfer price pursuant to...

Sinief Act 26/22 was published on 6 July in the Official Gazette, amending the Sinief Act 01/21, which establishes a differentiated treatment of ICMS applicable to natural gas processing. The Sinief Act 26/22 aims at improving and bringing greater...

The Constitutional Amendment 123/22, enacted on July 15, made relevant changes to the federal and state tax regime applicable to fuels, especially to establish competitiveness differential for biofuels in relation to fossil alternatives. Among the...

Since July 1st, when it was published in the extra edition of the Official Gazette of the State of Rio de Janeiro, it is in force the Decree 48,145/22, which sets the maximum ICMS rate in the State for internal transactions and services...

Leonardo Martins and Andre Araujo de Andrade The Attorney General's Office of the State of Rio de Janeiro (PGE-RJ), through the Joint Service Order - OSC PG-02/PG-03/PG-19 01/2022, regulated the procedures necessary for the administrative...

In a unanimous judgment, the 1st Section of the Superior Court of Justice (STJ) granted the claim of the National Treasury to reaffirm its position regarding the possibility of maintaining the seizure of bank deposits via the BACENJUD system even...

Taxpayers were surprised earlier this year by an important decision of the Superior Court of Justice (STJ) in the case file of Special Appeal 1.826.124/SC. The 1st Class of the Court unanimously recognized the possibility of customs review even...

Defined as the "word of the year" of 2021 by Collins Dictionary, the NFT, acronym for the term Non-Fungible Token (or, in Portuguese, ”token não fungível”), has increased the attention from entrepreneurs and investors in recent years....

A recurrent and still controversial topic in the scope of the Administrative Tax Appeals Board (Carf) is the application of an isolated fine of 50% for non-payment of Corporate Income Tax (IRPJ) and Social Contribution on Net Profits (CSLL)...

The Federal Supreme Court (STF) has unanimously decided to consider April 20, 2021, as the starting date for the effects of the decisions handed down in Direct Actions of Unconstitutionality (ADIs) that declared state laws unconstitutional...

Companies have challenged in court the obligation to pay social security contributions (employer's, third-party, and Environmental Labor Risk - RAT) on amounts paid to minor apprentices, considering the peculiar nature of this labor relationship....

In response to the great expectation of taxpayers on the topic, the Brazilian Federal Revenue Service (RFB) and the Attorney General of the Brazilian Treasury (PGFN) issued, on May 3, 2022, Notice 09/22, which deals with the settlement of tax debts...

Tax

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

STJ: premature revocation of the Asset Law tax incentive is illegal

Transfer price for IRPJ and CSLL calculation

CONFAZ improves rules applicable to natural gas processing

Constitutional Amendment modifies biofuel tax regime

State of Rio de Janeiro sets maximum ICMS rate

Consensual settlement of ICMS shares on contracted claims

Maintenance of seizure via BACENJUD system

STJ affirms the position that the customs review are possible regardless of the clearance verification channel elected

How to tax NFTs

Unstable case law on the application of isolated fines simultaneously with ex-officio fines

Inheritances and donations from abroad are not subject to ITCMD until a complementary law is passed by the Brazilian Congress

Levy of social security contributions on amounts paid to minor apprentices

Transactions in cases of goodwill

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