In the 1st Panel of the Superior Chamber of the Administrative Council of Tax Appeals (CARF), a decision was issued that allowed the deduction of amounts resulting from the 13th salary and vacation bonus paid to direct employees in the calculation basis of Corporate Income Tax (IRPJ) and Contribution on Net Profit (CSLL), according to the understanding that such expenses were necessary, given that they were provided for in the company’s articles of association.
In addition, isolated fines previously applied by the Federal Tax Authority were waived due to failure to collect monthly IRPJ estimates, in order to avoid concurrent fines, given that the taxpayer had already been fined ex officio for failure to pay taxes in the annual adjustment, following the precedent of the judgment of the precedent created case no. 12571.720074/2016-46, judged in June 2023, which ruled out the concurrent application of fines.
