The Federal Court of Curitiba passed on a decision in relation to Process No. 5005596- 52.2015.4.04.7000/PR on May 6, 2016.The single court judgments finish off that a Brazilian taxpayer may remove from the calculation of its corporate income tax (CIT) (IRPJ) and social contributions (CSLL), results of its controlled foreign subsidiaries located in Argentina and Chile, until those results are effectively made available to the Brazilian controller. The decision signifies the first time the issue of controlled subsidiary results has been considered under in recent times amended controlled foreign corporation (CFC) rules commenced in May 2014 by Law No. 12,973/2014 and which has applied from January 1, 2015 unless adopted earlier.
