description
This article discusses the changes in the regulatory framework or research and development tax incentives in Brazil, regarding the restrictions on the eligible R&D expenditures of Federal Law no. 11,196/2005, Article 19, imposed on operations of contract R&D by the way of Normative Instruction no. 1,187/2011, Article 4, paragraph 9, vis-à-vis the legal security principle of tax law, to propose due interpretation and application to this legal regime on the described circumstances.