- Taxpayers face difficulties in offsetting PIS/Cofins credits
- Full credit offset may not be possible within five years
- Many taxpayers won lawsuits to exclude ICMS from PIS/COFINS tax base
- RFB states taxpayers have five years to offset tax credits
- Possibility of not fully offsetting credits within timeframe
- Judicial decision may be necessary to challenge limitation
Source: klalaw.com.br
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.