Additional SAT Contribution must be paid even if the company adopts protection measures (Interpretative Act RFB no 02/2019)

On September 23, 2019, it was published the Interpretative Act RFB no. 02/2019, which refers to the additional social security contribution to fund the special retirement (article 292 Normative Ruling RFB N. 971/2009), the so-called Additional SAT Contribution.
The Act interprets in a broad way that the company should pay social security contribution even if it adopts protection measures to neutralize or reduce the risk of exposure of workers to legal levels of tolerance, in the cases in which the special retirement cannot be avoided. A typical example of this Act would be for noise exceeding 85 decibels.
This is a questionable understanding and we are available to provide details on the possible discussions.
Please let us know should you need any further clarification, as well as to explore the details of such regulation, including the possibility of filing a judicial measure questioning the levy of social security contributions.
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