News

Superior Chamber of the CARF recognizes the definitiveness of losses after five years

The Superior Chamber of CARF has established a significant understanding for taxpayers: unpaid credits that have been written off in accounting can be considered as definitive losses after five years, even if they have not been judicially collected.

 

In an article published by our Tax Law team, we analyze the main points of this decision and its practical implications for companies dealing with defaults and tax planning:

 

• The non-necessity of judicial collection for recognizing losses;
• Alignment with the principles of reasonableness and administrative efficiency; and
• The legal security provided for deductions of losses based on current legislation.

 

This decision represents an important precedent regarding the deductibility of losses for IRPJ and CSLL, especially in an economic scenario of high default rates.

 

Access the full analysis here (available only in Portuguese).