The 2nd Panel of the Superior Court of Justice (STJ), in an unprecedented decision, ruled out the taxation of IRPJ and CSLL on investment subsidies, which are tax exemptions granted by law as an incentive for the implementation or expansion of economic enterprises.
The case concerned an ICMS tax benefit granted by the State of Paraná, which was considered an investment subsidy, since Complementary Law No. 160/2017 and, therefore, the STJ ruled out the levy of IRPJ and CSLL on such amounts.
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