Comentários ao Processo nº 13839.001516/2006-64 do CARF
Autor | Pontieri |
“AGIO NA AQUISIÇÃO DE AÇÕES - AMORTIZAÇÃO - A pessoa jurídica que, por opção, avaliar investimento em sociedade coligada ou controlada pelo valor de patrimônio liquido e absorver patrimônio da investida, em virtude de incorporação, fusão ou cisão, pode amortizar o valor do ágio com fundamento econômico com base em previsão de resultados nos exercícios futuros, contabilizados por ocasião da aquisição do investimento. A amortização poderá ser feita a razão de um sessenta avos, mensais, a partir da primeira apuração do lucro real subseqüente ao evento da absorção. No caso de deságio deverá - amortizar na apuração do lucro real levantado a partir do primeiro ano-calendário seguinte ao evento. O ágio também poderá ser amortizado por terceira pessoa jurídica que incorporar a investidora que pagou o ágio e incorporou sua investida. O legislador não estabeleceu ordem de seqüência dos atos que de incorporação, fusão ou cisão, não cabendo ao interprete vedar aquilo que a não proibiu.
ÁGIO NA SUBSCRIÇÃO DE AÇÕES - AMORTIZAÇÃO - O ágio na subscrição de ações deve ser calculado após refletido o aumento do património liquido da investida decorrente da própria subscrição. O ágio corresponde à parcela do valor pago que não beneficia, via...
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