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Goodwill and the Burden of Proof

Goodwill (ágio), amortisation and the administrative tax litigation that decides whether it holds

The thesis

Goodwill is only worth what the evidence supports. The future profitability appraisal is the centrepiece, and it must exist before the transaction, not after the tax assessment

What the study establishes

1

An appraisal produced after the fact carries reduced evidential weight in administrative tax litigation

2

A related-party transaction requires demonstration of an independent business purpose

3

Poorly supported amortisation creates a tax liability with an aggravated penalty

Download the study 20-page PDF, 2026 edition · in Portuguese

Contents