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Fatores que promovem discordâncias entre fisco e contribuinte a respeito da comprovação de hedge

2013; UNIVERSIDADE FEDERAL DE SANTA CATARINA; Volume: 10; Issue: 21 Linguagem: Inglês

10.5007/2175-8069.2013v10n21p25

2175-8069

Ralph Melles Sticca, Sílvio Hiroshi Nakao,

Corporate Taxation and Avoidance

This paper investigates factors that cause disagreement between tax authorities and taxpayers in regard to hedge validation in financial operations, which is a legal requeriment for the deducibility of losses over the income tax. A case-study, which was carried out in an exporting company that had been fined by Receita Federal do Brasil in 2008, showed that the attested measure of exposure to the ex-ante risk of variation in commodity prices and in exchange was not enough to avoid the aggravation of losses given the non-deducibility of such measure. This is due to the lack of management criteria as well as the lack of accounting criteria standarts, which was corroborated in documentary research and content analysis over decisions made by the Receita Federal do Brasil on this issue from 1999 to 2010.