Fábio Bernardo
Attorney General’s Office extends deadline for negotiating tax debts with discounts
The Attorney General’s Office of the National Treasury published PGDAU Notice No. 4/2023, extending until December 28, 2023 the deadline for adherence to various negotiation modalities for debts registered as active federal debt. Negotiations include discounts on the value of debts, easy down payments, the possibility of using precatory payments and extended payment terms. During […]
Carf decision represents tax benefit for sugarcane producers
The article “CARF decision represents tax benefit for sugarcane producer”, by Fábio Bernardo, a tax lawyer at Marcos Martins Advogados, is featured in Nova Cana. The lawyer comments on the decision by CARF (the Higher Chamber of the Administrative Council for Tax Appeals) which authorized a rural producer to benefit from incentivized accelerated depreciation in […]
CARF allows rural producer to use tax benefit
The Superior Chamber of the Administrative Council for Tax Appeals ( CARF) has authorized a rural producer to benefit from accelerated depreciation in relation to sugarcane plantations, which allows for a significant reduction in the calculation of Corporate Income Tax (IRPJ) and Social Contribution on Net Profits (CSLL). The decision in favor of the taxpayer […]
Estadão | The impact of Provisional Measure 1.171/23 on financial investments, offshores and trusts abroad
Fábio Bernardo, a lawyer specializing in tax law, has written about the impact of Provisional Measure 1.171/2023 on financial investments, offshores and trusts abroad. In addition to updating the progressive personal income tax table, the measure imposes profound changes in the way investments abroad held by individuals resident in Brazil are taxed. Click here to […]
PIS, COFINS and ISS should not be part of the ISS calculation base
In a recent decision, the São Paulo State Court of Justice (TJSP) recognized that PIS, COFINS and ISS should not be included in the calculation basis of the Services Tax (ISS). This position is important for companies providing services, as it reinforces the understanding that has been forming in the judiciary about the concept of […]
Rosalito has its judicial reorganization plan approved
Part of the case involving a debt of R$70 million owed by Cerealista Rosalito, an important agribusiness company, was prepared by the law firm Marcos Martins Advogados.
STF to rule on constitutional scope of PIS and COFINS non-cumulative taxation
Fábio BernardoLawyer at Marcos Martins Advogados The Federal Supreme Court included one of today’s most important tax cases on its agenda for the 18th. This is a discussion on the scope of the constitutional principle of non-cumulative taxation for PIS and COFINS. The non-cumulative nature of these contributions is one of the most controversial issues […]
New TRF ruling limits the offsetting of credits from the exclusion of ICMS from the PIS and COFINS tax base
Fábio BernardoLawyer at Marcos Martins Advogados A recent preliminary injunction granted by the Federal Regional Court of the 3rd Region prevented the offsetting of credits resulting from the exclusion of ICMS from the PIS and COFINS calculation basis prior to March 15, 2017. The decision was handed down in a rescission action filed by the […]
Law passed to improve conditions for federal tax transactions
Fábio BernardoLawyer at Marcos Martins Advogados Law No. 14.375/2022, the result of the conversion of Provisional Measure No. 1090/21, was published in the Federal Official Gazette on June 22, 2022. The measure, which initially dealt with the renegotiation of debts under the FIES, was amended by the National Congress and provisions were included, modifying the […]
