Bruno Calfat Advogados represented one of the largest steel companies in the country in a tax enforcement proceedings brought by the Federal Government, which sought to collect amounts allegedly owed for Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL), related to the amortization of goodwill from intragroup transactions generated from corporate restructuring operations.
With the legal assistance of the firm and its work before the Federal Court of the 2nd Region, the steel company filed a motion to stay the tax enforcement, which was upheld by the 11th Federal Tax Enforcement Court of Rio de Janeiro, recognizing the unenforceability of the debts registered as outstanding by the National Treasury.
Both parties appealed the ruling, but their appeals were dismissed by the Federal Court of Appeals for the 2nd Region (TRF2).
The judgment on the merits of the motion to stay the enforcement, as it stands, represents a multi-billion reais economic benefit to the steel company.