The Federal Supreme Court will analyze the constitutionality of the 30% limit on the compensation of tax losses and negative bases of the contribution on net profit - CSLL.

Although the STF has already pronounced on the subject, he understood Minister Marco Aurelio that the Court failed to assess the alleged breach to certain tax constitutional principles.

The decision uttered in the extraordinary appeal nº 344.994 / PR faced only alleged offenses to the principles of priority and irrepreation. Now, in the extraordinary appeal nº 591.340 / SP, the question will be analyzed under the perspective of the principles of contributory capacity and typicality.

The new decision may determine the case-law of the Court on the subject and to ensure that other companies beyond the applicant benefit from their own demands.