On Aug. 15, BRZ Tax released proposal to join tax dispute transaction.
BRZ Tax published proposal of the Attorney General's Office of National Treasury and BRZ Tax to join transaction in tax dispute of relevant, widespread legal controversy.
Highlights
Tax credits may be transacted in tax litigation of relevant and widespread legal controversy, in administrative or judicial litigation re non-retroactivity of place concept.
Provided for in Art. 15-A of Law 4.502, of 1964, as amended by Law 14.395, of 2022.
For the application of Minimum Taxable Value (VTM) in transactions between interdependent parties, for levying the Tax on Industrialized Products (IPI).
Fines related to disputes referred to in item 1.1, including qualified fines, may be included in transaction, where the same discounts applied to principal debt will apply.
Transaction will only be concluded if it is found that, on date of adherence to Notice, there is an inscription in active debt, legal action, embargo on tax execution or claim.
If registration of procedures relate to more than 1 controversy, taxpayer may separate
Adherence to transaction may be formalized as of publication until 7:00 p.m., Nov. 28.
Discounts granted in transaction cases will not be included in calculation of tax base.
For taxes, such as: IRPJII; CSLL; Contribution to Social Integration and Public Servant Asset Formation Programs, PIS/Pasep; and to Social Security Financing (Cofins).
Effectiveness
Notice 52 shall come into force on the date of its publication in the Official Gazette.
