Comentários ao Processo nº 10183.003857/2004-76 do CARF
| Autor | Pontieri |
CSLL. Compensação de Bases Negativas - Limite de 30%. Atividade Rural – Súmula nº 53 do CARF: Nos termos do voto da Conselheira Relatora, Karem Jureidini Dias, o recurso da Fazenda Nacional não foi conhecido, pois a matéria já está pacificada no CSRF/CARF com base na Súmula nº 53 do Conselho. Os demais Conselheiros seguiram o entendimento da Relatora em votação unânime.
A Súmula CARF nº 53 assim dispõe: “Não se aplica ao resultado decorrente da exploração de atividade rural o limite de 30% do lucro líquido ajustado, relativamente à compensação da base de cálculo negativa de CSLL, mesmo para os fatos ocorridos antes da vigência do art. 42 da Medida Provisória n° 1991-15, de 10 de março de 2000.”
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