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Grupo Multi loses $200 million tax case at CARF

Dispute centers on import operations allegedly made through a shell subsidiary to conceal real buyer.

Multi, multilaser, appliance

By Brazil Stock Guide – Grupo Multi S.A. (B3: MLAS3), the parent company of Multilaser, said Brazil’s Administrative Council of Tax Appeals (CARF) has ruled against the company in three tax cases totaling R$1.116 billion (about $200 million). The ruling, issued on October 15, ended in a 3–3 tie and was decided against the company by the casting vote of the panel’s chair, as allowed under Law 14,689/2023.

The disputes stem from audits conducted by Brazil’s Federal Revenue Service in 2022, related to import operations carried out through Proinox Brasil Ltda., a Grupo Multi subsidiary. Tax authorities accused Proinox of acting as a front company to conceal the group’s real import activities, characterizing the case as “interposição fraudulenta”— a fraudulent use of third parties in customs operations. The audits imposed fines equivalent to 100% and 10% of the customs value of the imported goods, under Decree-Law 1,455/1976 and Law 11,488/2007.

According to Grupo Multi’s 2024 Reference Form, the three cases — Nos. 15165.720019/2022-17, 15165.720020/2022-17, and 15165.720021/2022-53 — are in the appeals phase at CARF, with the company classifying the risk of loss as “possible.” Grupo Multi was named as a joint debtor in some of the cases, while Proinox is the main defendant in two of them. The October 15 decision marks the close of the administrative stage, with the company expected to evaluate potential judicial remedies once the full ruling is published.

In a statement, the company said it will continue taking all necessary legal measures to defend its rights, in coordination with its lawyers, and noted that the decision does not change the loss assessment or require any accounting provisions at this time.

In the latest results, Grupo Multi reported net revenue of R$929.7 million, up 21.7% from the previous quarter, with a net profit of R$19.8 million and EBITDA of R$30.8 million. The company ended the quarter with R$498.9 million in cash and net debt of R$157.9 million, reversing prior losses and posting R$84.4 million in net income for the semester.

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