The 6th Tax Region understood in Answer to Consultation n. 42 that the calculation basis of substitutive social security tax provided by Section 8 of Law n. 12,546/2011 is the operational gross revenue. Therefore, only the interest charged from clients in term-payment sales shall be included in the taxable basis, since this is an addition to the sales price.

The decision emphasized that interests on the sale of goods that are not contemplated in the taxpayer’s corporate goal, as well as discounts obtained, earnings on fixed income investments and earnings resulting from exchange variation are not included in the gross revenue since they are financial revenues.

(Answer to Consultation n. 42, 04.02.2013, Official Gazette, 04.05.2013).