General Communication – Profit Sharing
In June 2016, the Administrative Council of Tax Appeals (Carf) issued several decisions on the validity of the Profit and/or Result Sharing Plans (PLR), and one of them expressed that the execution of the Profit-Sharing Plan after the start of its assessment period would disqualify its nature, conferring a salary nature upon the amounts paid under an agreement executed "late."
Thus, this communication seeks to remind you that it is important to execute, throughout 2016, the company's Profit and/or Result Sharing Agreements whose assessment period is the calendar year of 2017 (January to December 2017).
This is also recommended for Agreements that do not follow the calendar year but whose fiscal period starts in the first months of the year.
We are at your disposal to assist you in implementing any possible Profit Sharing Agreement for 2017 or, also, in discussing alternatives to minimize the risks if implementation is not possible at this moment.