Findings at a glance
- Completeness of the data basis
- Business-specific benchmark
- Requirements for counter-evidence
- Burden of proof and its reversal
3× exceeded · 1× met
Completeness of the data basisexceeded
Indirect assessment is permitted only where it is impossible to prove and quantify directly and exactly the elements indispensable to the tax base.
CitationLei Geral Tributária, Art. 87 lit. b)
What we provideA full census across all accounts, suppliers and product groups. No sampling is used; 100 per cent is the upper limit and cannot be exceeded by any method.
Requirements for counter-evidenceexceeded
The impossibility must follow from named anomalies: absent or insufficient accounts, late or irregular records, refusal to produce, concealment, destruction, or multiple sets of books for the purpose of simulation.
CitationLei Geral Tributária, Art. 88
What we provideA closed system: purchasing, production, masses, unit counts, sales channel and revenue support one another. A single incorrect figure shows up against the others.
Further information — 2 axes
Business-specific benchmarkexceeded
The triggers include unjustified deviation from objective indicators of activity.
CitationLei Geral Tributária, Art. 87
What we provideThe calculation rests on the recipes and quantities of the audited business, not on an industry average.
Burden of proof and its reversalmet
Indirect assessment is subsidiary to direct assessment.
CitationLei Geral Tributária, Art. 87 und Art. 88
What we provideThe evidence is prepared so that the reversal of the burden remains traceable and the counter-evidence engages with the calculation, not with the objection.