Bloco K

Bloco K – O tempo é curto!

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Previsto a ser obrigatório a partir de Janeiro de 2016, o bloco K será parte integrante da Escrituração Fiscal Digital ICMS/IPI (SPED FISCAL), substituindo o Registro de Controle da Produção e Estoque, o livro modelo 3.

Este livro destina-se à escrituração dos documentos fiscais e dos documentos de uso interno dos estabelecimentos industriais, dos equiparados à industrial e dos atacadistas, de forma obrigatória, relativos às entradas e saídas, à produção e às quantidades relacionadas aos estoques de mercadorias.

Os artigos 216 e 217 do Regulamento do ICMS do estado de São Paulo (RICMS-SP) especificam a forma de escrituração deste livro e as informações que deverão ser mantidas à apresentação ao fisco, permitindo, inclusive, a utilização de controles alternativos, desde que contenham os registros obrigatórios e que previamente comunicado às autoridades fiscais federais e estaduais de seu uso.

O bloco K será, basicamente, a escrituração digital do livro modelo 3, no SPED FISCAL.

Porém, o fisco requer que o arquivo seja alimentado com diversas informações, sem as quais não é possível sua validação e transmissão, fato que, normalmente, na escrituração eletrônica atual, não é impeditivo à geração do livro, pois o mesmo não é submetido à auditoria do sistema validador da EFD.

Para a geração do Bloco K são necessárias diversas informações distribuídas em registros de outros blocos, como o registro de identificação das unidades de medidas, tabela de identificação do item (produtos e serviços), consumo específico padronizado, fatores de conversão de unidades, dentre outros, todos contidos no Bloco 0 do SPED FISCAL.

Concentrando a análise do bloco K em uma empresa industrial, que normalmente possui operações mais complexas, tanto no plano físico como no fiscal, se comparado às equiparadas a industrial ou às atacadistas, é possível notar, especificamente no registro “tabela de identificação do item (produtos e serviços)” que serão requeridas classificações dos produtos, identificando seu tipo ou estágio de fabricação.

Tais produtos, na indústria, deverão ser segregados nas seguintes classificações: matéria-prima, embalagem, produto em processo, produto acabado, subproduto, produto intermediário e outros insumos.

O Bloco K exigirá registros de informações concernentes aos insumos consumidos na fabricação dos produtos, assim como o volume de produção verificada no período de apresentação do SPED FISCAL. Tais dados serão retirados, respectivamente, das fichas técnicas dos produtos e das ordens de produção dos mesmos.

A ficha técnica de cada produto será alimentada com a lista de insumos que compõe sua fabricação, por unidade, com as respectivas quantidades consumidas no processo de sua industrialização.

Já as ordens de produção identificarão a quantidade de cada tipo de produto fabricada no período.

Logo, pela combinação dessas informações, através de operações simples de multiplicação efetuadas pelo programa, será possível identificar na EFD a coerência entre a quantidade total consumida de cada insumo e sua aplicação na produção em andamento ou na produção acabada.

Com tudo isso é imprescindível à administração da empresa, especialmente aos gestores da produção, da controladoria e do departamento de custos, o conhecimento da terminologia contábil, a parametrização das fichas técnicas e a realização dos controles físicos das etapas do processo produtivo, fazendo uso das ordens de produção.

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Todo esse contexto requer a manutenção de uma contabilidade de custos integrada à contabilidade fiscal, para que as informações sejam inseridas no SPED de maneira adequada.
A qualidade dos controles internos mantidos pelos setores responsáveis é que definirá a correta apresentação dos dados.

Vejam que será possível ao fisco identificar a consistência do consumo dos insumos informados e se as variações são aceitáveis. Isso poderá ser verificado, não só pelo acompanhamento do comportamento da produção do próprio contribuinte em vários períodos, como pela comparação dos parâmetros com empresas que fabricam produtos análogos.

É certo que várias empresas mantêm na contabilidade de custos controles suficientes ao atendimento do Bloco K. Outras sequer desenvolveram informações sobre os custos de seus produtos ou ao menos estabeleceram nível de detalhamento necessário para a melhor administração desses recursos.

Algo que talvez tenha passado despercebido dos empresários e dos profissionais das áreas contábil/fiscal da empresa, é que as informações do Bloco K, que são dados sobre a movimentação física dos estoques, associadas às informações fiscais sobre os valores monetários das entradas e saídas de mercadorias, apresentadas em outros blocos do próprio SPED Fiscal como nas demais EFD, proporcionam ao fisco informações completas que servirão para o cálculo ou confirmação do custo dos produtos (CPV) ou mercadorias vendidas (CMV) lançado no resultado da empresa.

Isso faz com que as empresas tributadas pelo lucro real, e as do lucro presumido que escrituram a contabilidade, fiquem sujeitas ao questionamento de seus resultados, caso os apresentem divergentes daquele obtido pelo fisco num eventual recálculo de seu CPV/CMV.

Às empresas do lucro presumido, o alerta se refere à distribuição dos lucros, visto que a alteração no resultado, para menor, eventualmente, pode acarretar em distribuição acima do lucro contábil, sujeitando à retenção de imposto de renda dos valores excedentes.

Não há escapatória.

A empresa industrial, equiparada ou atacadista que deixar de apresentar as informações requeridas no Bloco K ficará suscetível às penalidades previstas nas legislações que tratam da EFD.

Existem discussões acerca da disponibilização de informações sigilosas, como a fórmula ou composição dos produtos, muito embora resguardados pelo sigilo fiscal gera desconfiança por parte dos empresários. Porém, até que novas instruções sejam publicadas, permanecem inalteradas as regras para a apresentação das informações do Bloco K.
Portanto, as empresas precisam se preparar para a geração das informações requisitadas, principalmente aquelas que não fizeram quaisquer movimentos nesse sentido, pois o prazo é exíguo.

A preparação para o atendimento dessa exigência necessita de tarefas complexas, como a formulação da ficha técnica de todos os produtos fabricados pela empresa, a elaboração dos modelos de ordem de produção, inserção destes documentos no sistema de informação, assim como sua integração com os demais módulos administrativos que se relacionam com essas operações.

O processo de análise e implantação dos elementos necessários para o Bloco K exigirá a participação de profissionais especializados, sobretudo nas áreas de engenharia, almoxarifado, controladoria (focado na contabilidade de custos) e da tecnologia da informação para que todas as etapas e requisitos sejam cumpridos.

Por isso, alertamos aos empresários e gestores das empresas obrigadas à entrega desse novo bloco do SPED Fiscal para que, imediatamente, se já não o fizeram, iniciem os trabalhos de preparação da empresa ao atendimento dessa nova obrigação.

Quer entender melhor sobre essas novas atualizações entre em contato com a equipe TBS saiba mais detalhes.

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