The Administrative Council of Tax Appeals (CARF) issued binding decision 115 (Súmula no. 115) on 11 September 2018. The new decision approving that, the calculation  method of the ‘ 60% Profit Price Less Profit Method (PRL 60)’ provided for in Normative Instruction SRF No. 243, of 2002, does not violate the provisions of article 18 , item II , of Law No. 9,430 of 1996, as amended by Law 9.959 of 2000.

Since this judgement was adopted in the form of a binding decision (súmula), the cases that are currently covered by the CARF will be decided consequently, that is, taxpayers assessed for not having observed Normative Instruction 243/2002 will have their demands rejected.