Questão jurídica principal
Whether the sale of the PMO sector had to be treated as one composite transaction or as separate supplies
Decisão extraída
The transfer formed one indivisible economic transaction and had to be treated as a single service, not separate deliveries.
Fundamentação extraída
The contract showed an intent to transfer an entire production unit, including tangible and intangible assets and most staff; the civil-law structure chosen by the parties should be respected, and the mixed bundle of deliveries and services was economically one operation.