Comentários ao Processo: 13808.001566/99-91 do CARF
| Autor | Alexandre Pontieri |
Recorrente: Contribuinte
Recorrida: Fazenda Nacional
Ementa da Decisão recorrida: “DESPESAS FINANCEIRAS. MÚTUOS COM SÓCIO. DESNECESSIDADE DIFERENÇA DE TAXA DE JUROS. TAXA COBRADA PELOS BANCOS. TAXA DE APLICAÇÃO FINANCEIRA (CAPTAÇÃO). GLOSA.
Despesas financeiras decorrentes de empréstimos tomados ao sócio a taxas de juros iguais às cobradas pelos bancos são desnecessárias se a empresa possui recursos iguais ou superiores aplicados no mercado financeiro remunerados a taxas de juros de captação.
DESPESAS INDEDUTÍVEIS. Os ajustes por adição à base de cálculo da Contribuição Social sobre o Lucro Líquido...
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