Questão jurídica principal
Whether the tourism promotion levy violates equal treatment by exempting agricultural primary production
Decisão extraída
No. Agriculture may be exempted because its tourism dependence is low; compensation for land rights does not fall within the taxable business income targeted by the levy.
Fundamentação extraída
The levy is a cost-bearing tax justified by the economic benefit derived from tourism. Different treatment is permissible where the excluded income is not the kind of entrepreneurial benefit on which the levy is based.