In a decision issued by the 2nd Panel of the Administrative Council of Tax Appeals (“CARF”), the levy of social security contributions on the Profit and Results Sharing (“PLR”) paid to non-employee directors was maintained.
According to what was reported in the decision, the payment made is part of the contribution salary of non-employed directors, and is therefore subject to taxation through social security contributions, given that the possibility of excluding the contribution from amounts received as PLR, according to the letter of the law, only concerns amounts received by employees and non-employed directors.
