Comentários ao Processo: 16327.001851/2001-16 do CARF
| Autor | Alexandre Pontieri |
Recorrente: Contribuinte
Recorrida: Fazenda Nacional
Ementa da Decisão recorrida: “COFINS. EMPRESA DE FACTORING. OPERAÇÕES COM TÍTULOS OU CRÉDITOS. ATIVIDADE OPERACIONAL. As operações que envolvam compra e venda de títulos ou direitos creditórios caracterizam-se, de acordo com a legislação de regência, como atividade operacional de empresas de factoring, sujeitando-se à incidência da Cofins, devendo a receita ser reconhecida na data da operação. NORMAS PROCESSUAIS. DECADÃSNCIA. O prazo de decadência da Cofins é de dez anos, contados do exercício seguinte àquele em que o lançamento poderia ter sido...
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