Declaração sobre a utilização dos recursos em moeda estrangeira decorrentes do recebimento de exportações

Declaração sobre a utilização dos recursos em moeda estrangeira decorrentes do recebimento de exportações

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A Receita Federal do Brasil (RFB) divulgou as seguintes normas com esclarecimentos sobre a aplicação da legislação tributária federal:

a) CSL – Retenção na fonte – Pagamentos a cooperativas de trabalho médico – Operadoras de seguro saúde (Solução de Consulta nº 10/2018): os pagamentos efetuados por pessoas jurídicas de direito privado, operadoras de seguro saúde, a cooperativas de trabalho em decorrência dos serviços profissionais de medicina e correlatos de que tratam os itens 3, 20, 21, 24, 32 e 34, do § 1º do art. 647 do RIR/1999, por essas últimas prestados ao segurados daquelas, sujeitam-se à retenção na fonte da CSL, devendo as cooperativas de trabalho médico discriminar em suas faturas ou apresentarem faturas segregadas dos valores a serem pagos a cada prestador de serviço, sob pena de a retenção recair sobre o valor total da fatura emitida pela cooperativa, observando-se que os valores relativos aos serviços profissionais de medicina e correlatos de que tratam os itens 3, 20, 21, 24, 32 e 34, do § 1º do art. 647 do RIR/1999:
a.1) prestados por cooperados, pessoas físicas, que estarão sujeitos à retenção na fonte, em nome da cooperativa, da CSL de que trata o art. 30 da Lei nº 10.833/2003, à alíquota de 1%;
a.2) prestados por ambulatório, banco de sangue, casa de saúde, casa de recuperação ou repouso sob orientação médica, hospitais e pronto-socorro, cooperados ou credenciados, quando os atendimentos ocorrerem nas dependências dos estabelecimentos, e desde que presente a subordinação técnica e administrativa, ou seja, que o serviço seja prestado pelo profissional de medicina em nome da pessoa jurídica titular do estabelecimento e não em seu próprio nome, os quais não sofrerão retenção na fonte da CSL, de que trata o art. 30 da Lei nº 10.833/2003;
a.3) executados por profissionais de medicina, mediante intervenção de sociedades, cooperadas ou credenciadas, realizados nas dependências dos mesmos estabelecimentos, citados na alínea “b” anterior, sem subordinação técnica e administrativa a estes estabelecimentos, os quais estão sujeitos à retenção na fonte da CS L, de que trata o art. 30, da Lei nº 10.833/2003, à alíquota de 1%, em nome de cada estabelecimento prestador do serviço;
a.4) que poderiam ser prestados em caráter individual e de forma autônoma, mas que, por conveniência empresarial, são executados mediante a intervenção de sociedades, cooperadas ou credenciadas, os quais estão sujeitos à retenção na fonte da CSL, de que trata o art. 30, da Lei nº 10.833/2003, à alíquota de 1%, em nome de cada estabelecimento prestador do serviço;

b) IRRF – Serviços de encaminhamento de hóspedes e intermediação de negócios (Solução de Consulta Cosit nº 11/2018): sujeitam-se à incidência do Imposto de Renda Retido na Fonte (IRRF), à alíquota de 1,5%, as importâncias pagas ou creditadas por pessoas jurídicas a outras pessoas jurídicas a título de remuneração:
b.1) pelo encaminhamento de hóspedes, sendo da agência de turismo a responsabilidade pela retenção e pelo recolhimento do imposto;
b.2) pela intermediação de negócios voltados para a realização de feiras, exposições de negócios, congressos, convenções e congêneres, sendo da fonte pagadora a responsabilidade pela retenção e pelo recolhimento do imposto;

c) IRPJ/CSL – Adoção do valor justo como custo atribuído (Deemed Cost) do ativo imobilizado – Neutralidade fiscal dos ajustes (Solução de Consulta Cosit nº 17/2018): por via de regra, os ganhos e perdas de avaliação a valor justo não repercutirão efeitos tributários, desde que atendidas as exigências constantes dos arts. 13 e 14 da Lei nº 12.973/2014, regulamentados pelos arts. 97 a 104 da Instrução Normativa RFB nº 1.700/2017;

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d) Cofins/PIS-Pasep – Recob – Alteração no coeficiente de Redução – Majoração da alíquota específica  (Solução de Consulta Cosit nº 23/2018): a majoração da alíquota específica da contribuição para o PIS-Pasep e da Cofins incidente sobre a receita bruta auferida na venda de álcool por produtor ou importador optante pelo Regime Especial de Apuração e Pagamento da Contribuição para o PIS/Pasep e da Cofins incidentes sobre Combustíveis e Bebidas (Recob), decorrente da alteração do coeficiente de redução promovida pelo art. 1º do Decreto nº 7.997/2013, entrou em vigor em 1º.09.2013, devendo ser aplicada a partir dessa data, nos termos do seu art. 2º, inciso I;

e) Cofins/PIS-Pasep – Autopeças – Alíquotas concentradas (Solução de Consulta Cosit nº 25/2018): continuam sujeitos à tributação concentrada prevista na Lei nº 10.485/2002 os produtos compreendidos no código da NCM 8413.91.00, Ex 01, constante de seu Anexo I, atualmente classificados no código 8413.91.90, Ex 01, da TIPI, aprovada pelo Decreto nº 8.950/2016.

(Soluções de Consulta Cosit nºs 10, 11, 17, 23 e 25/2018 – DOU 1 de 28.03.2018)

Fonte: Editorial IOB
Data: 28 de março de 2018
Acesso: 29 de março de 2018

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