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CSRF: Amounts received for constitution on onerous usufruct of shares are taxed

The Superior Chamber of Tax Appeals recently confirmed an understanding of the 3rd Ordinary Class of the 1st Chamber of the 1st Judgment Section, which, by a vote of quality, determined that the value received for the grant of usufruct onerous and temporary usufruct should be taxed by the IRPJ.

For judges, the amounts received as temporary grant of usufruct of shares must receive the same tax treatment of a lease, and should be understood as taxable operating income.

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