Questão jurídica principal
Whether debt interest must be taken into account when determining the rate-determining hypothetical annual income for a short tax period.
Decisão extraída
Yes. A strict maturity-based exclusion is impermissible where it distorts the hypothetical annual income and no representative annual result would be reached without the interest deduction.
Fundamentação extraída
Rate determination under short-period taxation must approximate economic ability to pay. The assessment may not ignore regular debt-interest burdens merely because the tax period was too short for a due date to occur; otherwise the result departs from the taxpayer's actual economic capacity.