CONTRIBUIÇÃO SOCIAL PREVIDENCIÁRIA SOBRE AS ATIVIDADES AGROINDUSTRIAIS E A (IN) APLICABILIDADE DA REGRA DE IMUNIDADE TRIBUTÁRIA AO SENAR"
CONTRIBUIÇÃO SOCIAL PREVIDENCIÁRIA SOBRE AS ATIVIDADES AGROINDUSTRIAIS E A (IN) APLICABILIDADE DA REGRA DE IMUNIDADE TRIBUTÁRIA AO SENAR"
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DOI: https://doi.org/10.22533/at.ed.9942405065
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Palavras-chave: agroindústria, contribuições sociais, jurisprudência, imunidade tributária.
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Keywords: agroindustry, social contributions, jurisprudence, tax immunity.
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Abstract: This work aimed to present the question of the incidence of social contribution on income arising from activities that escape the legal concept stipulated as typical of agro-industries. To this end, topics that justify these controversies were addressed. With this, we sought to answer questions that relate to the specific creation of Social Contributions for Social Security owed by the agroindustry and which are based on gross revenue. In addition, we sought to answer which activities and revenues should fall on this calculation basis and also other information that could justify the choice of the proposed theme. As for the methodology used in the research, it was qualitative in nature, through the laws contained in the legal system; books by authors dealing with taxation laws on agribusiness products, as well as academic works with a theoretical basis on the subject. As for the results obtained in this study, analyzed based on three interpretative currents that guide the jurisprudence on the legal nature of the social contribution on the agroindustry, it can be understood that the social security contribution of the agroindustry would focus only on the revenues arising from the commercialization of its production. With regard to SENAR and the respective immunity on the income arising from exports, it can be understood that there are solid grounds to support that the contribution destined to SENAR fits as a general social contribution (second interpretative current) and, therefore, applicable to tax immunity on export earnings.
- Daniel Garcia Mascareñas
- Roberta Vedana