In a decision issued by the 2nd Panel of the Administrative Council of Tax Appeals (“CARF”), the levy of social security contributions on the remuneration of interns was maintained, with the understanding that they perform activities compatible with those of employees hired under the CLT regime.
In the case analyzed, the company had a significantly larger number of interns than employees and partners, without the company presenting sufficient proof of the relationship of these interns.
According to one of the counselors who analyzed the case, the legislation does not determine a maximum number of interns that a company can have, in order to justify the incidence of social security contributions on the amounts received by them, however this was defeated and, by a majority vote, the incidence of said contribution was maintained.
