axable Event of PIS/Pasep and Cofins Contributions when Importing Services

Abstract

This study aims to examine the tax incidence on matrix-rule of PIS/Pasep and Cofins contributions due on service imports, under the Statute 10.865/2004. It is a subject that, in facing adequately, presupposes (i) evaluating constitutional grounds on the taxation of imported services under Brazilian Law; (ii) analyzing the incidence hypothesis; (iii) defining the concept of service and its theoretical difficulties – especially concerning the “resulting” term verified in the country under the terms of Article 1º, § 1º, Statute 10.865/2004 – analyzing specific situations, particularly on paying charter contract, demurrage, international freight, royalties and software; (iv) as well as studying the taxation consequences.