Post by account_disabled on Mar 4, 2024 10:33:49 GMT
As was already expected — and feared — by companies in the sectors benefiting from Perse (Emergency Program for the Resumption of the Events Sector), on November 1st, Normative Instruction No. 2,114/2022 was published, which listed a series of restrictions on their fruition. It is worth remembering that the program was implemented by Law 14,148 , of May 3, 2021, and aimed, among other objectives, at establishing "emergency and temporary actions aimed at the events sector to compensate for the effects resulting from isolation or quarantine measures carried out to combat the Covid-19 pandemic" (article 1); as well as the institution of "the Emergency Program for the Resumption of the Events Sector (Perse)" (article 2).
In addition to providing for a specific type of tax transaction for taxpayers in the events sector, the Perse Law also provided, in its article 4, for the reduction of the rates of some taxes to 0%, for a period of 60 months, namely: (1 ) Contribution to PIS/Pasep; (2) Contribution to Social Security Financing (Cofins); (3) Social Contribution on Net Profit (CSLL); (4) Corporate Income Tax (IRPJ). Said device had EL Salvador Mobile Number List initially been vetoed by the President of the Republic; this veto, however, was overturned by the National Congress, so that the rule in question was promulgated on March 18 of this year, when it became valid and in force. Almost nine months after its advent, the normative instruction in question, under the pretext of regulating the benefit, ended up unduly causing some restrictions.
And the first of these concerns the requirement that, for the purposes of enjoying the reduced rates, the revenues and results arising from the benefited CNAE codes (Ordinance ME 7163/03) are related to the activities listed in article 2 of the IN: "Art. 2º The tax benefit referred to in article 1º consists of the application of the rate of 0% (zero percent) on the revenues and results of economic activities referred to in Annexes I and II of Ordinance ME No. 7,163 , of June 21, 2021, as long as they are related to: I – holding or marketing congresses, fairs, sporting, social, promotional or cultural events, business fairs, shows, parties, festivals, symposiums or shows in general, event houses, social and children's buffets, nightclubs and concert halls; II – hotels in general; III – administration of film screening rooms; and IV – provision of tourist services, as regulated by article 21 of Law No. 11,771, of September 17, 2008.
In addition to providing for a specific type of tax transaction for taxpayers in the events sector, the Perse Law also provided, in its article 4, for the reduction of the rates of some taxes to 0%, for a period of 60 months, namely: (1 ) Contribution to PIS/Pasep; (2) Contribution to Social Security Financing (Cofins); (3) Social Contribution on Net Profit (CSLL); (4) Corporate Income Tax (IRPJ). Said device had EL Salvador Mobile Number List initially been vetoed by the President of the Republic; this veto, however, was overturned by the National Congress, so that the rule in question was promulgated on March 18 of this year, when it became valid and in force. Almost nine months after its advent, the normative instruction in question, under the pretext of regulating the benefit, ended up unduly causing some restrictions.
And the first of these concerns the requirement that, for the purposes of enjoying the reduced rates, the revenues and results arising from the benefited CNAE codes (Ordinance ME 7163/03) are related to the activities listed in article 2 of the IN: "Art. 2º The tax benefit referred to in article 1º consists of the application of the rate of 0% (zero percent) on the revenues and results of economic activities referred to in Annexes I and II of Ordinance ME No. 7,163 , of June 21, 2021, as long as they are related to: I – holding or marketing congresses, fairs, sporting, social, promotional or cultural events, business fairs, shows, parties, festivals, symposiums or shows in general, event houses, social and children's buffets, nightclubs and concert halls; II – hotels in general; III – administration of film screening rooms; and IV – provision of tourist services, as regulated by article 21 of Law No. 11,771, of September 17, 2008.