This is precisely what happens in the case under

firoj3131

discussion, in which there is no formal rule linking Carf to Cosit's demonstrations. To apply the principle of prohibitionshould also not be forgotten that the theory of administrative self-binding is not only beneficial to individuals, who will have their fair expectations preserved in situations that have not been covered by the legal system. The public administration also benefits greatly from its effects, as acting in a coherent manner will imply speed and integrity in responding to consultative demands; reducing litigation in administrative litigation; reducing the risks and costs of legal-administrative relations; "and greater acceptance by individuals of their decisions and, consequently, the reinforcement of the legitimacy of their action .

Clearly noticing these elements, during the debates in the trial of Case counselor Liziane Angelotti Meira presented a statement that was as intelligent as it was courageous, summarizing the theme: "there is no point in being more realistic than the king" . For all these reasons, the EX Mobile Phone Numbers decision made at the debut of the new composition of the 3rd Panel of the CSRF is to be applauded, interpreting the "service result" based on the understanding set out in Divergence Solution No. 3/2020, when it removed the PIS charge /Cofins-importation of service for the simple economic benefit of the contractor residing in Brazil.



In doing so, it materially gave light to the principle of equality and self-binding of public administration, a fact that more than justifies the change in the fate of the column presented to our readers today.Brazilian IR credit in the how the scenario could change in 2022 Rafael Benevides September 14, 2022, 1:04 pm InternationalTax Historically, the United States universal basis taxation system allows crediting of taxes paid abroad by controlled entities. Allowing credit on taxes paid abroad avoids double taxation of multinational groups and follows the logic of the concept of export neutrality ( capital export neutrality ), on the basis of which American rules were designed.