Ernesto Borges AdvogadosErnesto Borges Advogados

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The Firm

Seven decades of history always looking to the future

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Areas of expertise

The firm stands out in the most comprehensive areas of specialties and economic sectors.

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Publications

Dedutibilidade das Perdas em Operações de Crédito no CARF Racional, Impactos e Documentação

Tax 24/04/2026

Deductibility of Credit Losses before the CARF: Rationale, Impacts, and Documentation
The deductibility of losses arising from credit operations rests on three pillars: avoiding taxation on non‑existent wealth, preserving the reliability of taxable income (lucro real), and preventing abuse. From an economic standpoint, when a credit becomes irrecoverable—due to statute of limitations, insolvency, or definitive write‑downs granted in renegotiations—there is an effective reduction of net assets,…
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Tax 07/04/2026

Pre-Filled Annual Income Tax Return: A Revolution in the Filing of Individual Income Tax
The Pre-Filled Annual Income Tax Return represents one of the most significant advances implemented by the Brazilian Federal Revenue Service (Receita Federal do Brasil) in the process of filing the Individual Income Tax Return (IRPF). Its primary objective is to optimize tax compliance, minimize the occurrence of errors, and strengthen fiscal conformity. For the preparation…
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Tax 26/03/2026

The Legal Perspective on “Pejotização”: Civil Contracts, Subordination, and Limits
The Office of the Prosecutor General (PGR) recently submitted to the Federal Supreme Court (STF) a legal opinion that may redefine how Brazil addresses so‑called pejotização and the jurisdiction for adjudicating disputes involving service‑provision contracts. According to the PGR, the STF has already established firm case law recognizing the constitutionality of alternative hiring models that…
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Ernesto Borges Advogados
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