The first that emerged was about the need for legal entities

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That carry out the activities described in Annex II to have, at the time of the law's enactment  registered with the Ministry of Tourism, which, as already confirmed in some judicial decisions, it would violate the principle of legality, competition, free enterprise, among other principles and rules. Another very salutary point, however, and not yet so widespread or noticed, concerns companies that, despite carrying out the activities listed in Annex I (in theory, "self-applicable"), have only one or two Cnaes included in Annex I , to the detriment of other (perhaps several) Cnaes that you have.

Furthermore, the legislation remained silent regarding the need for the Cnae to be primary or secondary. Some discussions that have taken place say that revenues should be "segregated" by the company's Cnaes, that is, only Cnaes included in Perse would have the right to a 0 rate, while revenues originating from other Cnaes EX Mobile Phone Numbers would not have this benefit. Furthermore, there may be situations in which the company has revenue from activities that would not necessarily be related to the Cnaes it owns and are in Perse.



Thus, in the absence of a legal provision and also of a formal and transparent position of the RFB itself, various positions and interpretations have been disseminated through the most diverse portals and YouTube channels, including the Associations, which are in contact with the top leadership of the RFB. RFB, without, however, express and assertive guidance regarding which position the taxpayer should take and follow. The fact is that the legislative omission in this regard of the Regulatory Power has caused and is causing a serious threat to the liquid and certain rights of taxpayers, who, despite having Cnaes contained in the aforementioned Ordinance, do not know what the position of the RFB will be in the future.