Tax planning strategy in view of the latest Carf's jurisprudence

Article

by Andressa Moreira
25.Mar.2022

Our lawyer Andressa Moreira, specialized in Tax Law, published an article on the Consultor Jurídico (Conjur) portal entitled "Tax planning strategy in view of the latest Carf's jurisprudence."

In view of the latest decisions by the Carf recognizing the deductibility of the accrued interest on equity (IOE) and those arising from horizontal mergers, much has been discussed on the matter within the scope of tax planning. Therefore, the lawyer summarized the legal decisions on the matter and commented on the context for this background: with the pandemic, many companies decided to protect their cash, opting to withhold IOE payments to their partners and shareholders.

She also commented that, even though there is still no consolidated legal decision on this matter, the trend is that companies are beginning to study the possibility of using IOE as a means of tax planning, as well as the immediate distribution of the accrued IOE for purposes of deducting such expenses from the IRPJ and CSLL tax bases.

Check out the full article at the link: https://www.conjur.com.br/2022-mar-22/andressa-moreira-estrategia-planejamento-fiscal