Dedutibilidade das perdas não técnicas de energia elétrica do lucro real e da base de cálculo da CSLL

Abstract

ARTICO, Murilo Vianna. Deductibility of Non-Technical Electricity Losses fromTaxable Income and the CSLL Calculation Basis. Bacharelor’s thesis(Bachelor’s Degreein Law) – Faculty of Law, Pontifical Catholic University of São Paulo, São Paulo, 2025.This bacharelor’s thesis aims to analyze the possibility of deducting, from taxable incomeand the CSLL (Social Contribution on Net Profit) calculation basis, the expenses related tonon-technical electricity losses incurred by public service concessionaires engaged in thedistribution of electric power within the scope of their business activities. To that end, theresearch encompasses an examination of the legal framework governing income taxation inBrazil, the deductibility rules applicable to expenses under the IRPJ (Corporate Income Tax)and CSLL regimes for entities subject to the actual profit method (lucro real), the contextsurrounding non-technical electricity losses, the positions issued by the federal taxauthorities, and the relevant administrative jurisprudence (given that, at the time of this thesis,the judicial courts have not yet addressed this matter)