A autonomia fiscal entre filial e matriz: uma análise da jurisprudência do Superior Tribunal de Justiça

Abstract

The present work aims to analyze the legal consequences arising from the divergence about the legal nature of the subsidiaries in relation to the headquarters in the light of the STJ's understanding. Thus, it aims to define the various consequences of the understandings already signed. For this purpose, a qualitative approach is used, carrying out a bibliographic review and analysis of documents, such as decisions of the Superior Court of Justice, legal, legal, doctrinal examination, scientific articles and electronic journals in order to unravel the consequences resulting from a new understanding of the STJ , especially with regard to the possibility of issuing a certificate of tax compliance (CND) to the branches of a company, whose head office has debts with the Treasury and its implications.