Post by account_disabled on Mar 12, 2024 6:21:13 GMT
Cofins of financial institutions, inclusion of PIS/Cofins in their own calculation bases, PIS/Cofins/calculation base and ISS, PIS and Cofins and incidence on revenue arising from the leasing of movable assets, PIS/Cofins and exclusion from the calculation basis of presumed ICMS credits. In other words, the Union's balance sheet, duly analyzwill ultimately burden the universe of taxpayers. Thus, in the BGU, there is an item, among others, designated by legal demands classified as probable loss (PGFN), ined, shows that there is something wrong with these contributions or with the way in which they are viewed by the tax authorities.
These disputes total more than R$848 billion, classified as a possible loss. Furthermore, there are contingencies whose loss is remote and which are not subject to disclosure. All of these liabilities were recognized in accordance with AGU Ordinance No. 40/15 and amendments, as well as Complementary Law No. 101/01, Fiscal Responsibility Law and accounting standards relating to provisions and Belgium Phone Number Data contingent liabilities. These facts demonstrate a repeated attitude on the part of the public authorities of not reflecting on the warnings of doctrine and scholars, reiterating the collection of taxes that do not comply with constitutional principles in their collection. and which, in the future, will have to be returned, plus interest.
Such an attitude seems to us to have an impractical effect of increasing the Union's current revenue, initially, however, heavily burdening the budget in the future, including adding interest expenses that were not foreseen, in addition to procedural costs that burden the party loser, in this case the tax authorities. In this sense, it seems to us that it would be reasonable for the RFB's technical positions to be more widely discussed with society and heard from experts, as is the case abroad, thus preventing Brazilian taxpayers from bearing the costs, both of the personnel involved and financial.
These disputes total more than R$848 billion, classified as a possible loss. Furthermore, there are contingencies whose loss is remote and which are not subject to disclosure. All of these liabilities were recognized in accordance with AGU Ordinance No. 40/15 and amendments, as well as Complementary Law No. 101/01, Fiscal Responsibility Law and accounting standards relating to provisions and Belgium Phone Number Data contingent liabilities. These facts demonstrate a repeated attitude on the part of the public authorities of not reflecting on the warnings of doctrine and scholars, reiterating the collection of taxes that do not comply with constitutional principles in their collection. and which, in the future, will have to be returned, plus interest.
Such an attitude seems to us to have an impractical effect of increasing the Union's current revenue, initially, however, heavily burdening the budget in the future, including adding interest expenses that were not foreseen, in addition to procedural costs that burden the party loser, in this case the tax authorities. In this sense, it seems to us that it would be reasonable for the RFB's technical positions to be more widely discussed with society and heard from experts, as is the case abroad, thus preventing Brazilian taxpayers from bearing the costs, both of the personnel involved and financial.