Planejamento tributário e suas possíveis patologias na jurisprudência atual do Carf

Abstract

This work has the purpose of study issues and practices of tributary planning, verifying how the planning must be executed na the causes that can endanger it, as well as defining the effects of the legal acts, that may imply elision, evasion or fiscal elusion. But, mainly, the study seeks to analyze the recent understanding of CARF (Administrative Council of Tax Appeals) about tax planning, and the situations that constitutes simulation, law fraud, or rights abuse in the practice. It has been verified that the collegiate decides with strict observance of the law, according to the doctrinal understanding about the theme.