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"Internal goodwill" amortization is possible according to the Administrative Court

|Approved Changes|Brazil
Brazil

The Administrative Court (ConselhoAdministrativo de RecursosFiscais - CARF) recently gave its decision in the case of GerdauAçominas S/A v. National Treasury(Administrative Proceedings n. 10680.724392/2010-28), ruling in favour of the taxpayer regarding the possibility to amortize – for corporate income tax (Imposto de Renda das PessoasJurídicas - IRPJ) purposes – the goodwill generated in an internal reorganization ("internal goodwill"). Details of the decision are summarized below.

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