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SOC Attestation
Independent opinion attesting to the commitment of service providers to sound internal controls
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Audit and review of financial statements
Credibility of your company's accounting activities in accordance with the legislation in force
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Assurance of Non-Financial Reports
It aims to meet the needs of the business, being able to contemplate different bases and sectorial and global development guidelines
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Assurance of Integrated Reporting and Sustainability Reports
Differential for rendering accounts and demonstrating the engagement of organizations in relation to sustainable practices and their generation of value
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Assistance in accounting definitions
Quality, comparability and transparency of financial information in your company
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Accounting, Labor and Tax Compliance
Permanent diagnostics and advice to raise the level of controls and mitigate risks
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Pre-Audit Diagnosis
Diagnostics capable of offering support according to the purpose and needs of the business
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Assessment reports for consolidations, spin-offs, and mergers
Technical evaluation of net assets at book value or of net assets adjusted to market prices
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Capital Markets
Complete analysis and preparation for strategic fundraising operations
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Business Consulting
Approaches compatible with technologies that support corporate decision-making and stimulate innovation
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Strategy & Transactions
Performance of operations and capital structure to enable more efficient corporate transactions
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FIDS – Forensic, Investigation & Dispute Services
Identification, protection and prevention of risks to preserve business integrity and security
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Risk and Compliance - BRS
Risk management, process improvement to achieve strategic objectives
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Judicial Administration in Business Recovery
Global teams and structures to work with the deep knowledge, legality and ethics that the issue requires
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Business Restructuring and Recovery
Assertive plans and agile actions to recover your company's strategy and performance
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Global Mobility Services
International mobility programs in compliance with local tax legislation and optimized costs
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Home page
Financial Statements
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Transfer Pricing
Review or elaboration of calculations that allow the most assertive compliance in operations abroad
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Labor & Social Security
Identification of existing risks and opportunities according to the current moment and future perspectives
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Direct tax
Agile strategies for complying with laws and enabling regional and sectoral tax incentives
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Indirect tax
Specialized support capable of increasing legal certainty involving different laws and jurisprudence
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International Tax
Analysis and planning of scenarios in different jurisdictions, with integration into the Brazilian scenario
It should be noted that the termination of the PAT was already the object of the Tax Reform proposal (Bill no. 2.337/21), but that due to the controversy involved, it ended up being withdrawn from the proposal.
According to article 641 of the Income Tax Regulation - RIR/18, the PAT tax benefit is a deduction of the amount equivalent to the application of the tax rate (15%) on the sum of the costing expenses incurred in the calculation period of the income tax owed.
Regarding the amendments to the aforementioned Decree, we highlight the following aspects:
- The same amount of benefit is granted by the company to all its workers.
- Beneficiary legal entities may not demand or receive any type of discount or imposition of discounts on the contracted amount or other amounts and direct or indirect benefits not directly related to the promotion of the worker's health and food safety.
- Higher-income workers may be included in the meal program, provided that all workers hired by the beneficiary legal entity earning up to five minimum Brazilian wages are assisted.
- It should only cover the portion of the benefit that corresponds to the value of, at most, one minimum Brazilian wage.
Given the foregoing, it is important to highlight that with the limitations imposed on the use of the tax benefit about expenses related to the PAT, it is expected that the value of the benefit calculated from December 11, 2021, will be reduced in many beneficiary companies, given that meal expenses for workers who receive compensation above 5 minimum Brazilian wages, as well as those who receive the meal benefit in an amount higher than the minimum Brazilian wage (about BRL 1,100.00 currently), will no longer be part of the PAT expenses for the purpose of deducting the income tax due.
Finally, we warn you that there are already signs in the market that such changes could lead to several lawsuits by the beneficiary companies, given that the changes were introduced by a Decree, which in the legal system is hierarchically inferior to Act No. 6,321/76, which instituted the PAT.