Post by nurnobisorker65 on Feb 11, 2024 4:20:11 GMT -5
That there are decisions, such as Ruling nº 108-08.859, which maintained the suspension of the exemption upon proof, by the tax authority, that the football club had failed to comply with some of the requirements of article 12, §2 of Law No. 9,532/97. In this type of case, the legal issue regarding the right to exemption on the part of football clubs is not discussed, but rather compliance with the obligations necessary for its enjoyment. In other cases, it is possible to verify that, at no time, did the tax authority raise or prove non-compliance with the requirements for benefiting from the exemption. In these situations, the basis used in the tax work is of a strictly legal nature, that is, the revocation of the exemption given that the activity carried out by football clubs is characterized as a true.
Exercise of economic activity. In Judgment No. 1402.002.182, the ex officio appeal filed in view of the DRJ's decision was upheld, which gave reason to the club's objection on the understanding that even though Article 18 of Law No. 9,532/97 revoked the income tax exemption for football clubs (originally provided for in article 30, of Law 4,502/64), this was characterized as a civil Belgium Email List association and, under this modality, fell within the sole paragraph of the aforementioned article, since it shelters the exemption based on in article 15 of the same law. The ordinary Carf group, however, reformed the aforementioned decision as they understood that there was no need to talk about the provision of services by the club, in.
Addition to the fact that the autonomy of sports entities to define their organization and functioning cannot be used to exempt from tax incidence. The aforementioned decision was reformed, by the 1st Panel of the Superior Chamber of Tax Appeals (CSRF), in the judgment of Decision No. 9101-003.648, which adopted the reasons for decision espoused by the DRJ [5] . The decision highlights that it is an incontrovertible fact that the assessed entity, in addition to being a football team, is a recreational club that provides multiple services to its members and that, in this case, only revenues linked to the football club were taxed, which would allow the conclusion that the tax authority had recognized that, in essence, the club.
Exercise of economic activity. In Judgment No. 1402.002.182, the ex officio appeal filed in view of the DRJ's decision was upheld, which gave reason to the club's objection on the understanding that even though Article 18 of Law No. 9,532/97 revoked the income tax exemption for football clubs (originally provided for in article 30, of Law 4,502/64), this was characterized as a civil Belgium Email List association and, under this modality, fell within the sole paragraph of the aforementioned article, since it shelters the exemption based on in article 15 of the same law. The ordinary Carf group, however, reformed the aforementioned decision as they understood that there was no need to talk about the provision of services by the club, in.
Addition to the fact that the autonomy of sports entities to define their organization and functioning cannot be used to exempt from tax incidence. The aforementioned decision was reformed, by the 1st Panel of the Superior Chamber of Tax Appeals (CSRF), in the judgment of Decision No. 9101-003.648, which adopted the reasons for decision espoused by the DRJ [5] . The decision highlights that it is an incontrovertible fact that the assessed entity, in addition to being a football team, is a recreational club that provides multiple services to its members and that, in this case, only revenues linked to the football club were taxed, which would allow the conclusion that the tax authority had recognized that, in essence, the club.
