Despesas de pró-labore no exterior são dedutíveis no Lucro Real?

Despesas de pró-labore no exterior são dedutíveis no Lucro Real?

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Para efeito de apuração do IRPJ/CSLL (no Lucro Real), o valor reembolsado pela pessoa jurídica no Brasil a sua matriz ou a empresa do mesmo grupo empresarial domiciliada no exterior no valor da remuneração de sócio-administrador ou profissional expatriado residente no Brasil da pessoa jurídica domiciliada no Brasil pago no exterior, mediante “invoice” apresentada por sua matriz ou por empresa do mesmo grupo empresarial, é dedutível.

Observe-se que tais despesas, para fins de dedutibilidade, devem ser necessárias às atividades da pessoa jurídica no Brasil e à manutenção da fonte produtora e desde que sejam também despesas usuais em seu ramo de negócio.

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Bases:  Regulamento do Imposto de Renda, Decreto 3.000, de 26 de março de 1999, alínea “a” do art. 685 e Solução de Consulta Cosit 378/2017.

Fonte: Guia Tributário
Data: 05 de setembro de 2018
Acesso: 10 de setembro de 2018

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