Our Tax team has prepared a comprehensive analysis of the judgment of Tema 914, which will be reviewed by the Supreme Federal Court next week.
The discussion centers on the possible unconstitutionality of CIDE applied to amounts sent abroad due to licensing agreements, technology transfers, technical services, and royalties.
The decision could directly impact companies that carry out this type of operation. More than that, the modulation of effects may limit the right to restitution to only those who have already filed a lawsuit. It’s time to evaluate strategies to protect your tax rights. Check out the full informative in Portuguese, with comments from partners Anna Flávia de Azevedo Izelli Greco and Rodrigo Prado Gonçalves here (available only in portuguese).
