Post by xyz3500 on Feb 22, 2024 6:56:57 GMT
The use of summaries in the judgments of administrative processes by tax bodies, such as the Administrative Council of Tax Appeals (Carf), has been discussed by the legal community, which alleges that the decisions of the Judiciary are affronted in at least eight entries. reproduction Summaries approved by Carf in September confront the Judiciary Reproduction In September, the administrative court approved 33 new jurisprudential precedents and rejected three others. The analysis of 50 entries was on the agenda. In October, the Ministry of Economy created and revoked an ordinance that established the Federal Tax Administration Summary Committee. Under the act, only Revenue and PGFN could approve the statements.
Summary 126 For tax expert Allan Fallet , from the Amaral Veiga firm, the first impression is that some matters are being decided by a casting vote or by a majority, without the discussions being sufficiently mature for the approval of a summary. Furthermore, some topics are awaiting definition by the higher courts. "The case of summary 126 was decided until the beginning of by a casting vote. Only at the end of , with yet another change in composition, was the understanding maintained, but now by a Israel Mobile Number List majority vote. However, there are several arguments raised by taxpayers and advisors contrary to the premises used, including those that ruled out the application of the institute of spontaneous reporting based on Carf Summary 49 and the understanding of the STJ", explains the lawyer.
Summary 126 addresses the scope of spontaneous complaints, and was given binding effect in April this year. Summary 127 Regarding summary 127 , which deals with Cide's impact on the contracting of technical services from abroad, Fallet explains that the issue still needs to be pacified by the higher courts. RE 928.943 is being analyzed by the STF, which discusses the delimitation of the constitutional profile of the contribution levied on amounts paid, credited, delivered, employed or remitted, to residents or domiciled abroad, as remuneration resulting from contracts that have by object licenses for the use and transfer of technology, technical and administrative assistance services and the like. "And in the STJ a case (REsp 1655415) was returned to the Court of origin to await the publication of the ruling on the respective exceptional appeal representing the controversy.
Summary 126 For tax expert Allan Fallet , from the Amaral Veiga firm, the first impression is that some matters are being decided by a casting vote or by a majority, without the discussions being sufficiently mature for the approval of a summary. Furthermore, some topics are awaiting definition by the higher courts. "The case of summary 126 was decided until the beginning of by a casting vote. Only at the end of , with yet another change in composition, was the understanding maintained, but now by a Israel Mobile Number List majority vote. However, there are several arguments raised by taxpayers and advisors contrary to the premises used, including those that ruled out the application of the institute of spontaneous reporting based on Carf Summary 49 and the understanding of the STJ", explains the lawyer.
Summary 126 addresses the scope of spontaneous complaints, and was given binding effect in April this year. Summary 127 Regarding summary 127 , which deals with Cide's impact on the contracting of technical services from abroad, Fallet explains that the issue still needs to be pacified by the higher courts. RE 928.943 is being analyzed by the STF, which discusses the delimitation of the constitutional profile of the contribution levied on amounts paid, credited, delivered, employed or remitted, to residents or domiciled abroad, as remuneration resulting from contracts that have by object licenses for the use and transfer of technology, technical and administrative assistance services and the like. "And in the STJ a case (REsp 1655415) was returned to the Court of origin to await the publication of the ruling on the respective exceptional appeal representing the controversy.