Amortization of goodwill (ágio): the “real acquirer” theory before the CARF
The deductibility of the amortization of goodwill (ágio) for purposes of Corporate Income Tax (IRPJ) and Social Contribution on Net Profits (CSLL) is one of the most frequent and highest-value tax disputes arising from acquisitions of equity interests. A series of recent decisions indicates that the Federal Administrative Tax Court (Conselho Administrativo de Recursos Fiscais […]