Comentários ao Processo: 18471.002113/2004-09 do CARF
Autor | Alexandre Pontieri |
Recorrente: Fazenda Nacional
Recorrido: Contribuinte
Ementa da Decisão recorrida: “RENDIMENTOS DE RESIDENTES E DOMICILIADOS NO EXTERIOR - OPERAÇÕES DE EMPRÉSTIMOS REALIZADASENTRE EMPRESAS CONTROLADAS E EMPRESA CONTROLADORA - REMESSA DE JUROS - TÍTULOS DE CRÉDITO INTERNACIONAIS - COLOCAÇÃO DE FIXED RATE NOTES NO MERCADO INTERNACIONAL - INCIDÊNCIA NA FONTE REDUZIDA À ALÍQUOTA ZERO - CONTRATOS EM VIGOR EM 31/12/1999 - PRAZO MÍNIMO MÉDIO PARA AMORTIZAÇÃO DE 96 MESES - As operações de captação de recursos financeiros a curto prazo realizadasentre as empresas subsidiárias da contribuinte no exterior e banqueiros internacionais não se confundem com as operações de empréstimo a longo prazo realizadasentre as empresas subsidiárias no exterior e a empresa controladora no Brasil - são negócios jurídicos distintos. Inocorre resgate antecipado das Fixed Rate Notes em razão de transferência internacional de Reais realizada entre a empresa controladora no Brasil (emitente dos títulos de crédito) para as suas empresas subsidiárias no exterior (adquirentes dos...
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