Our partner Tatiana Del Giudice Cappa Chiaradia participated in an article published in Valor Pro, an exclusive channel for Valor Econômico subscribers.
She commented on the recent decision of the Federal Supreme Court (STF) which, by authorizing the automatic reversal of final and unappealable decisions when there is a later decision by the STF to the contrary, authorized, in this specific case, the collection of the Social Contribution on Net Profits (CSLL) disallowed in the past. The measure may impact countless taxpayers in a similar situation and result in the collection of incalculable amounts.
The lawyer explained that, in the case of CSLL, the decision affects all taxpayers that have already been assessed and whose defense was only regarding the res judicata. “It is necessary to evaluate how the audits classified these amounts, if there was provisioning, to assess the damages.
The Union should have a study, within the budget, of how much this represents.”
The full article can be accessed here: https://lnkd.in/eJB4Waq