The Superior Court of Justice (STJ) allows the deduction of interest on equity capital paid out of time from the corporate income tax (IRPJ) and social contribution on net profit (CSLL) tax base.

In the judgment held on November 12, 2025, the First Section of the Superior Court of Justice (STJ), unanimously , ruled on Topic 1319 (Repetitive) and established the following thesis:

It is possible to deduct interest on equity (JCP) from the tax base for Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL), when calculated in a fiscal year prior to the shareholders’ meeting decision authorizing its payment.

The decision by the First Section of the Superior Court of Justice (STJ) validated the previous understanding of the 1st and 2nd Panels, which was already favorable to taxpayers, in the sense that there is no legal prohibition on the deduction of interest on equity (JCP) from previous fiscal years. Having been judged as a “repetitive” case, the STJ’s decision must necessarily be followed by the other instances of the Judiciary and by the Administrative Council of Tax Appeals.