O PAPEL DAS HOLDINGS NO PLANEJAMENTO TRIBUTÁRIO E EMPRESARIAL

REFLEXÕES SOBRE AS MUDANÇAS INTRODUZIDAS PELA REFORMA TRIBUTÁRIA

Abstract

This paper analyzes the role of holding companies from a tax perspective, considering the fiscal impacts of their incorporation and operation, as well as the effects of the recent Brazilian tax reform (Constitutional Amendment No. 132/2023). The research adopts a descriptive approach, with bibliographic and documentary reviews, encompassing doctrine, legislation, and reports on tax changes. The study examines the concept of holding companies, their classifications, incorporation processes, applicable tax regimes, the incidence of ITBI, IR, CSLL, and ITCMD, as well as succession and asset planning strategies. The results indicate that, when legitimately and transparently structured, holding companies enable tax optimization, revenue centralization, reduction of succession-related costs, and asset protection. It is observed that the tax reform, although primarily focused on consumption taxation, does not directly affect most holding companies, but requires continuous monitoring of regulatory changes. This study contributes to the academic community by systematizing the legal and tax aspects of holding companies and to society by providing support for strategic decision-making by families and businesses.