Brazil's Superior Court of Justice (STJ) ruled that stock options granted to company directors, officers, and employees are not considered compensation for income tax purposes, but are instead subject to capital gains tax upon the sale of the shares. This decision was made under the 'repetitive appeal' mechanism, setting a precedent for tax authorities like the Federal Revenue Service. The ruling counters the Federal Revenue's argument that stock options should be taxed as indirect compensation when exercised, with the court affirming they are a commercial contract.