In a decision issued by the Administrative Council of Tax Appeals (CARF), it was decided through the casting vote that taxes with suspended collectibility must be added to the calculation basis of the Social Contribution on Net Income (CSLL).

It was understood in the case analyzed that taxes with suspended collectibility should have the same accounting treatment as provisions and not expenses.

The ruling prevailed in the judgment, according to which there is no rule that authorizes the deduction of the tax base for taxes with suspended collectibility.