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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 5 May 2014

IRPJ and CSLL – premium and capital gain – internal contradiction

The tax assessment notice is to maintain an internal coherence. If the Tax Authorities defend the effec- tive inexistence of corporate…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 5 May 2014

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

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…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 29 Apr 2014

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

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…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 29 Apr 2014

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

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…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 29 Apr 2014

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

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…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 25 Apr 2014

STF - unconstitutionality of contribution of 15% of amounts paid to Labor Cooperatives

The Supreme Court ("STF"), under the regime of General Repercussion, declared the unconstitutionality of the contribution of 15% (fifteen percent) of…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 16 Apr 2014

RFB Normative Rule no. 1.457/14 – presumptive credit – doubtful debts

Normative Rule of the Federal Revenue of Brazil ("RFB IN") no. 1,457 was published on Mar. 11, 2014, providing for the reimbursement and ex-officio…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 16 Apr 2014

STJ – PIS and COFINS – charge on interest and adjustment for inflation arising from real estate sale agreements

The Second Panel of the Superior Court of Justice (STJ), in the trial of Special Appeal no. 1.432.952/PR, found unanimously that the PIS and COFINS…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 16 Apr 2014

TRF3 – PIS and COFINS – concept of input

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…
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Souza, Schneider, Pugliese & Sztokfisz Advogados | Brazil | 16 Apr 2014

Response to Inquiry no. 53/14 COSIT – SISCOSERV– establishment located in the Country of a legal entity domiciled abroad

Response to Inquiry no. 53/14, issued by the General Coordination of the Tax System ("COSIT"), was published on Mar. 10, 2014, establishing the…
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