In a judgment upheld by the 2nd Panel of the Superior Chamber of the Administrative Council of Tax Appeals (CARF), the incidence of social security contributions on scholarships paid to dependents of the taxpayer’s employees was ruled out, because the judges understood that educational scholarships are not considered wages, since there is no remuneration for the work performed by the employee.
The trial was based on Law 12,513/2011, which establishes that scholarships paid to employees or their dependents are not subject to taxation.
The result of the trial was not unanimous (6X4), however it represents a change in the position of the Superior Chamber.