Company in judicial reorganization makes tax transaction agreement with tax loss

Rafael ZanchettinLawyer at Marcos Martins Advogados A company in judicial reorganization entered into a tax settlement agreement with the Attorney General’s Office of the National Treasury (PGFN) to pay its debts using tax losses, obtaining a rebate of approximately 85% (eighty-five percent) of the amount of the credit, which could be paid in several installments. […]

CARF authorizes offsetting of tax losses without the 30% barrier

The article “CARF authorizes offsetting of tax losses without the 30% lock”, by lawyer Fábio Bernardo, is featured in the Lex Prime newspaper. In a recent decision favorable to taxpayer AES Tietê Energia S.A., CARF’s Superior Chamber of Tax Appeals removed the 30% lock for offsetting tax losses and the CSLL calculation base. Several companies […]

CARF authorizes offsetting of tax losses without the 30% barrier

Fábio BernardoLawyer at Marcos Martins Advogados In a recent ruling in favor of the taxpayer in a case involving the extinction by merger of the company AES Tietê Energia S.A – CARF ‘s Superior Chamber of Tax Appeals removed the 30% limit on offsetting tax losses and the CSLL calculation base. Several companies have already […]