A New Approach on the Results Concept to Identify the Occurrence of the ISS Exemption Rule on the Services Exports

Abstract

The purpose of this paper is to investigate the concept of the service’s result in order to characterize an export, based on the analysis of the service contract’s object. In order to do so, it is shown that by using the term “result”, laid down in the single paragraph of Article 2 of Supplementary Law 116/03, the complementary legislator has given a concept that can be understood as the very conclusion of the service or as the utility derives from it, depending on each specific case. In fact, in the present study an objective criterion is used to establish if, from the analysis of the service contract, the result might be understood as the conclusion or the usefulness of the service.