What was the “Thesis of the Century” and how could it impact the judgment...

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The judgment of the case related to ICMS constitutes a true landmark in tax judicial discussions. Since this judgment, several taxpayers have questioned other taxes that had, in their calculation basis, another tax.  

These lawsuits became known as “subsidiary theses” for the exclusion of ICMS from the PIS/COFINS calculation basis , which, in turn, is known as the “thesis of the century”. This thesis had a favorable outcome for the taxpayer, resulting in the recognition, by the Judiciary, that ICMS should not be part of the PIS and COFINS calculation basis.

This case is related to the legal dispute over the gambling data singapore exclusion of PIS and COFINS from their own calculation bases, precisely because it is based on the fact that taxes collected in favor of the taxing entity should not form the calculation base of other (or the same) taxes.

This occurs because, in the same way as ICMS, PIS and COFINS collected in favor of the Union, obviously, they are not incorporated into the taxpayer's assets, so they should not be understood as the basis for calculating PIS and COFINS, which is the companies' gross revenue.


Last but not least, we have the family holding company. This type of holding company is widely used to enable the matriarch or patriarch to transfer family assets through the donation of shares of the family, generally with the reservation of usufruct and the assignment of restrictive clauses that protect the entire family group against the actions of third parties outside the relationship. In this case, it is also advisable to draw up a family protocol, signed by all those involved and containing specific rules regarding the management of the assets.

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Estate and succession planning plays a crucial role in protecting assets and ensuring the proper transfer of assets to heirs. Through well-structured legal and tax strategies, it is possible to minimize conflicts, reduce tax burdens and provide financial security for future generations.