Comentários ao Processo nº 10768.014100/99-08 do CARF
| Autor | Pontieri |
“INCENTIVO FISCAL - PERC - CONCESSÃO -REGULARIDADE FISCAL. A prova da regularidade em relação aos tributos e contribuições federais a que alude o art. 60 da Lei n° 9.069/95, há que ser verificada no momento da fruição do incentivo fiscal ou na sua concessão, assim considerado o momento em que a administração tributaria analisa a opção feita pelo contribuinte em sua Declaração de Rendimentos. Entretanto, não se pode negar ao contribuinte o direito de mostrar sua regularidade fiscal no curso do Processo Administrativo, pois o objetivo da...
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