Publications | Tax 6wo2v
New Brazilian transfer pricing policy n3wf
Fundamentals of MP 1,152/22 and the arm's length principle
ICMS tax incentives can be extended for 10 years 3l1f6q
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 624x3s
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 4226
The conversion of MP 1,152/22, the taxpayer's option in 2023, and businesses restructurings
Unconstitutionality of 50% fine on unapproved tax offsets 3o382k
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 4sh6j
In the last article of the series, we take stock of the judgments of the 3rd of the CSRF.
Trilogy: Carf outlook in 2022 and perspectives for 2023 4sh6j
The main judgments of the 2nd of the CSRF.
Carf's outlook in 2022 and prospects for 2023 15t3l
Starting a series of three articles, we analyze the past year and take stock of the judgments of the 1st of the CSRF.
Federal Government presents a new package of fiscal recovery measures 535r1u
The package of measures, called "Zero Litigation", modifies the processing of istrative tax proceedings and establishes new models for settlements or installment plans.
Discount on AFRMM rates is revoked 14l68
Decree 11.374/23 recovers amounts of the Additional Freight for Renewal of the Merchant Navy in force until January 1st of this year.
Reduction os PIS and Cofins rates on financial revenues is revoked 5z4z2o
Decree 11,374/23 modifies rates established by Decree 11,322/22.
Carf's understanding on taxation of cost sharing 16k4n
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.
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