STF and STJ’ decisions regarding ICMS are the focus of this Tax Newsletter
Among the tax law news from the past month are STF decisions on retroactive ICMS, habitual tax debtors, and STJ rulings on ICMS DIFAL
Brazilian Supreme Court recognizes general repercussion on 30% cap for tax loss offset
The Court will assess whether the limitation can be waived in cases of merger, consolidation, spin-off, or company dissolution
Supreme Court acknowledges geberal repercussion in case concerning empolyee cost-sharning
The Supreme Court will decide if coparticipation in transport and meal allowances is subject to social security contributions
Federal Revenue Service publishes new notices with simplified conditions for settling tax debts
The Federal Revenue Service has published two new public notices for adhesion-based settlements, in which benefits may be granted without the need for individual negotiations with the tax authorities. Regarding Public Notice No. 5/2025, the Federal Revenue has conditioned the granting of discounts and the use of tax loss carryforward credits on the degree of […]
Supreme Court analyzes effects and deadlines for rescission actions
Ruling upholds deadlines and effects of rescission actions, introducing new theses on retroactivity and legal certainty
New public notices increase the amount of tax loss that can be used in tax settlements
Federal Revenue Service and PGFN increase the limit for using tax credits in the Integral Settlement Program from 10% to 30%
Key Tax Law Updates: Recent Rulings from STF, STJ, and TJ-RJ in the Latest Newsletter
Among other highlights in the Tax Law bulletin, the STF establishes rules for ICMS on transfers, and the STJ prohibits the offsetting of ICMS-ST
Federal Government changes the rules on remuneration of federal judicial deposits
Tax Newsletter: remuneration of federal judicial deposits, ruling on tax debts for assets acquired outside auction, and STF analysis of general repercussion on new issues
Provisional Executive Order limits judicial tax debt offset and restricts tax benefits
The rule has the same enforcement as a law and must be voted by Congress within 120 days, under penalty of effectiveness loss
Liberal Party files Direct Action against Provisinal Measure of tax incetives; check the newsletter
Tax Law newsletter also includes: STJ removes restrictions on the deduction of PAT; and Early execution of guarantee is prohibited
