Through Bill No. 512/23, a tax installment plan will be voted on specifically for taxpayers affected by the recent decision of the Federal Supreme Court (STF), which dealt with the possibility of deconstituting res judicata in Tax Law, when there is a change in understanding on the subject, which was called PERT-FIM.
According to what was included in the justification for the Bill, the Federal Supreme Court (STF), by allowing a change in understanding on the subject to overturn decisions that have already become final, ignores the principle of immutability of res judicata and legal certainty, which could generate billions in losses for companies, compromising investments in the country.
The Project, which is still pending approval, provides for six payment methods, with terms of 20, 15, 10, 5 and 2.5 years, in addition to payment in cash, with reductions in fines, interest and legal charges, with the possibility of using tax loss credits and negative CSLL calculation basis and court orders to amortize up to 70% of the remaining balance after the application of discounts.
