Questão jurídica principal
Whether the import of services from abroad by paying foreign athletes is constitutionally and statutorily subject to VAT.
Decisão extraída
Yes. The constitutional transitional provisions provided a sufficient basis, and the recipient of the foreign service is the taxable person.
Fundamentação extraída
The Constitution itself expressly regulated taxation of services received from abroad and the input-tax deduction. The ordinance therefore implemented, rather than created, the tax object.