Comentários ao Processo: 10166.000916/2003-81 do CARF
| Autor | Alexandre Pontieri |
Recorrente: Contribuinte
Recorrida: Fazenda Nacional
Ementa da Decisão recorrida: “COFINS. DECADÊNCIA. O prazo para a Fazenda Pública constituir ou exigir o crédito tributário relativo à Cofins é de dez anos. EXCLUSÃO DA BASE DE CÁLCULO. Incabível exclusão da base de cálculo da contribuição de valores relativos ao custo de serviços subcontratados de terceiros por não possuir, a contribuinte, meios próprios de realizá-los, sendo que os contratos de...
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