Post by firoj8240 on Jan 11, 2024 4:17:49 GMT
Law No. 14,148/2021, published on May 3, 2021, established Perse (Emergency Program for the Resumption of the Events Sector), providing benefits for a group of companies directly affected by measures to combat the Covid 19 pandemic. The program basically provides three tax benefits for the companies reached, the one we are now interested in being the reduction to zero, for sixty months, of the IRPJ, CSLL, PIS and Cofins rates. The rule seems simple, but several points in the law lead taxpayers to incorrectly interpret the program and its scope, starting with their own given name, which gives the false notion that the program only applies to the events sector.
The idea here is not to unravel the law in all its controversial points, but to analyze who is actually covered by the benefit of Perse's zero rate, especially in light of the recent edition of IN/RFdo this, we will analyze the framing technique chosen by the law and, thus, identify the correct interpretation that can be extracted from the recently edited IN. Legislative history PL nº 5,683, presented on December 22, 2020, initially referred only to the "events sector" Betting Number Data as the target of the rule. After intense debates and dozens of proposed amendments, the PL sent for presidential sanction included as members of the "events sector" and, therefore, as beneficiaries of Perse, companies that carry out, directly or indirectly, the following economic activities (according to text of L.
The law also provided that the Ministry of Economy would be responsible for listing and publishing the codes of the National Classification of Economic Activities (Cnae) that would fall within the concept of "events sector": "Article 2 (…) §2 Act of the Ministry of Economy will publish the codes of the National Classification of Economic Activities (CNAE) that fall within the definition of event sector referred to in §1 of this article." It is worth highlighting that, at the time of its publication, the law suffered important vetoes by the President of the Republic regarding part of the benefits provided, such as the reduction to zero of the IRPJ, CSLL, PIS and Cofins (PIS/ Cofins). The veto on this benefit, however, was overturned by Congress on March 17, 2022 [1] . Of the sectors benefiting from the zero rate As seen, Law 14,148/2022 assigned the Ministry of Economy the task of establishing which companies would fall within the concept of "events sector", establishing, through a list of Cnaes, which legal entities would be who carry out economic activities, directly or indirectly related to the "events sector" .
The idea here is not to unravel the law in all its controversial points, but to analyze who is actually covered by the benefit of Perse's zero rate, especially in light of the recent edition of IN/RFdo this, we will analyze the framing technique chosen by the law and, thus, identify the correct interpretation that can be extracted from the recently edited IN. Legislative history PL nº 5,683, presented on December 22, 2020, initially referred only to the "events sector" Betting Number Data as the target of the rule. After intense debates and dozens of proposed amendments, the PL sent for presidential sanction included as members of the "events sector" and, therefore, as beneficiaries of Perse, companies that carry out, directly or indirectly, the following economic activities (according to text of L.
The law also provided that the Ministry of Economy would be responsible for listing and publishing the codes of the National Classification of Economic Activities (Cnae) that would fall within the concept of "events sector": "Article 2 (…) §2 Act of the Ministry of Economy will publish the codes of the National Classification of Economic Activities (CNAE) that fall within the definition of event sector referred to in §1 of this article." It is worth highlighting that, at the time of its publication, the law suffered important vetoes by the President of the Republic regarding part of the benefits provided, such as the reduction to zero of the IRPJ, CSLL, PIS and Cofins (PIS/ Cofins). The veto on this benefit, however, was overturned by Congress on March 17, 2022 [1] . Of the sectors benefiting from the zero rate As seen, Law 14,148/2022 assigned the Ministry of Economy the task of establishing which companies would fall within the concept of "events sector", establishing, through a list of Cnaes, which legal entities would be who carry out economic activities, directly or indirectly related to the "events sector" .