The recently published COSIT Consultation Solution No. 104 of 2024 (“SC COSIT 104/2024”) confirmed the right of companies in judicial recovery (or with declared bankruptcy) to use the balance of Accumulated Tax Loss and Negative Calculation Base without the limitation of 30% (thirty percent), the general rule applicable to other taxpayers.
For more details, access the material we prepared on our website here (available only in portuguese).
