Souza, Schneider, Pugliese & Sztokfisz Advogados

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PIS/COFINS – ex-officio assessment – deduction from the tax basis of the IRPJ/CSLL

April 8 2014 The PIS and COFINS assessed jointly, in the same action, are to be deducted in the reestablish- ment of the Net Income and the Taxable Income. The…

RFB Normative Rule no. 1.455/14 – WHT on earnings to other countries

April 16 2014 Normative Rule of the Federal Revenue of Brazil ("RFB IN") no. 1.455/14 was published on Mar. 7, 2014, providing for the charge of the withholding…

IRPF – omission of income – current account located abroad

April 8 2014 The litigation phase initiates upon the objection to the demand. If there is no specific refutation of a given issue in the objection, then there is…

TRF3 – PIS and COFINS – concept of input

April 16 2014 The Third Panel of the Federal Regional Court of the 3rd Region (TRF3), in the trial of Appeal No. 0026598-69.2012.4.01.0000/DF, found unanimously…

The Superior Court of Justice resumes the trial of the taxation on profit of subsidiary located abroad

April 2 2014 On March 25, 2014, the First Panel of the Superior Court of Justice (STJ) resumed the trial of Special Ap- peal no. 1.325.709/RJ, which deals with…

IRPJ and CSLL – premium and capital gain – internal contradiction

May 5 2014 The tax assessment notice is to maintain an internal coherence. If the Tax Authorities defend the effec- tive inexistence of corporate…

IRPJ and CSLL – premium – proof of future profitability – amortized in the accounting records

May 5 2014 The law requires the assessment of the premium based on market value or on the expectation of future profitability to be based on the demonstration…

ISS levy on revenues deriving from commercial agency agreements with foreign companies to intermediate the sale of aircrafts to Brazilian clients

April 29 2014 This is an Administrative Tax Proceeding (PTA 2013-0.307.830-5) dealing with the charge of the Service Tax (ISS) on revenues deriving from commercial…

Debt Installment Plan – PPD – Law no. 15.387/2014 – State of São Paulo

April 29 2014 On April 16, 2014, the Governor of the State of São Paulo enacted Law No. 15,387, which created the Debt Installment Plan ("PPD") for the…

ISS levy on revenues deriving from the concession of guarantees and on revenues arising from activities to represent and attract clients for the concession of credit lines by foreign companies

April 29 2014 This is an Administrative Tax Proceeding (PTA 2013-0.183.869-8) that discussed the requirement of the ISS levied on revenues arising from the…