Imunidade das receitas decorrentes de exportação: sobre o posicionamento do STF quanto à CSLL

Abstract

The article focuses on the constitutional provision of tax immunity in its promoting aspect of fundamental rights. From this point, takes place an analyses of the immunizing coverage of item I, §2, art. 149 from the Federal Constitution - which deals with export income - by criticizing the position of the STF through the non-effect of the mentioned constitutional provision against CSLL. The issue is addressed in order to better interpret constitutional norms and goals, concluding that the immunity of the aforementioned item is applicable to the CSLL.