CARF: a premium calculated and paid month by month forms part of the social-security contribution base
The panel found that a premium calculated and paid every month, based on the service rendered in each period, has a compensation nature and does not fit the concept of an occasional gain. Monthly frequency was the deciding factor in denying the social-security exemption sought by the company.
The 1st Ordinary Panel of the 4th Chamber of the 2nd Section of CARF ruled, in a session held on June 11, 2026, on Acórdão No. 2401-012.645 (administrative case No. 12448.726880/2012-10, reporting counselor Leonardo Nuñez Campos, published on August 3, 2026). The panel upheld a social-security assessment on amounts paid by the company as a premium, calculated and settled monthly based on the service rendered in each period.
The company's argument
The assessed company argued that the premium, as a discretionary payment tied to productivity targets, had the nature of an occasional, non-recurring gain, which would rule out social-security contributions on the amounts paid to employees.
What tipped the decision: monthly frequency
For the panel, the central issue was not the label given to the payment, but how it was actually calculated and paid. Since the premium was calculated month by month, based on the service rendered in that specific period, the panel concluded that it had become part of the regular consideration for work, losing the occasional character that would justify non-incidence. In this scenario, the payment becomes part of the social-security contribution base, directly affecting the calculation base for employer and third-party social-security contributions.
The practical risk for companies
Premium or bonus programs that provide for calculation and payment in monthly cycles tend to be read by CARF as regular compensation, even when the company treats them internally as an occasional discretionary payment. The precedent reinforces that the frequency of calculation and payment, not just the wording of the internal policy, is what determines the legal nature of the payment for social-security purposes.
Premium and bonus policies with recurring calculation cycles fall within our Payroll Diagnostics & Review service, which reviews the frequency and nature of each payment item before it turns into a social-security liability. For a first, free read on the risk, use the Nexus Free Risk Check.
Does your company pay a premium or bonus with monthly calculation, treating the amount as occasional for social-security purposes? It is worth checking whether the calculation frequency holds up under CARF's view on regularity.