Fisco altera regulamentação da Declaração País-a-País

Fisco altera regulamentação da Declaração País-a-País

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Por Laura Ignacio

A quatro dias do prazo para o envio da Declaração País-a-País (DPP), a Receita Federal alterou a regulamentação da obrigação que deve ser entregue por multinacionais que tiveram, em 2016, receita consolidada igual ou maior que R$ 2,26 bilhões, após considerar as receitas de todas as unidades do grupo. As mudanças foram consideradas bem-vindas por advogados porque esclarecem – ainda que em cima da hora – como as empresas com controladora em país com o qual o Brasil ainda não tem tratado devem preencher a declaração.

O prazo para envio da DPP por meio da Escrituração Contábil Fiscal (ECF) vence no próximo dia 31. Por meio dessa declaração, se a controladora do grupo multinacional é brasileira, deverá descrever quais são suas atividades e das vinculadas no exterior, como é feita a alocação global de renda, quais são os impostos pagos e devidos, qual o lucro das suas unidades, onde a empresa gera empregos, onde se localizam os escritórios e ativos tangíveis, entre outros pontos. Tudo relativo ao ano de 2016.

Havia dúvidas das empresas com controladora nos Estados Unidos (EUA), país com o qual o Brasil não tinha “Acordo Multilateral de Autoridades Competentes do Common Reporting Standard” para troca de informações da DPP. Porém, segundo a Receita, o Brasil assinou esse acordo no dia 21 de julho. “O extrato do acordo deve ser publicado no Diário Oficial da União em breve para que seu texto possa ser colocado nos sites da Receita brasileira e da americana”, informa o Fisco por meio de nota.

Também havia insegurança no caso de a controladora localizar-se em país com o qual o Brasil tem acordo há muito tempo, mas só para a troca de dados deste ano em diante, como Espanha, França e Reino Unido.

Para o advogado Murilo Pires, líder da Tax Compliance da Grant Thorton, a Instrução Normativa nº 1.722, publicada ontem no Diário Oficial da União, deixou muito claro como as companhias com controladora nos EUA devem proceder. “É mandatório informar até 31 de julho pela DPP quem é o controlador responsável por compartilhar esses dados, número de registro e onde está localizada nos EUA”, afirma.

“O mesmo vale para as empresas dos países, como Espanha, França e Reino Unido, que ativaram a troca de dados pela DPP apenas relacionados a fatos geradores de 2017 em diante. Elas também devem informar quem é o controlador final e em qual país está, sem precisar entregar os dados financeiros de 2016”, diz o advogado Alexandre Siciliano, do Lobo & de Rizzo Advogados.

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Mas o tributarista Luís Eduardo Schoueri, sócio do Lacaz Martins Advogados, explica que elas ficam sujeitas a um mecanismo transitório. “Se o acordo com o país não for firmado até o fim deste ano, a empresa terá 60 dias para fazer a retificação da DPP. Nesse caso, ela mesma entrega os dados financeiros do grupo ou indica uma empresa substituta, localizada em país com o qual o Brasil tem acordo, para entregá-los”, afirma o advogado.

Siciliano alerta ainda que, segundo a IN 1.722, a Receita Federal também poderá intimar a empresa brasileira para retificar a DPP, em até 60 dias, se até o fim do ano o país onde está a controladora – como França, Espanha e Reino Unido – não acertar com o Brasil o cruzamento de dados de 2016.

As informações requisitadas pela DPP não são novas, mas mais detalhadas do que as já exigidas pela Receita Federal. Além disso, antigamente, para o Fisco brasileiro conseguir dados de outros países sobre as subsidiárias brasileiras era preciso uma boa fundamentação e paciência.

Se as multinacionais enviarem a DPP com omissão, informação inexata ou incompleta, deverá ser aplicada multa equivalente a 3%, não inferior a R$ 100, do valor omitido, inexato ou incompleto. Já se a empresa não enviar a DPP no prazo, a multa chega a R$ 1,5 mil por mês.

A Receita instituiu a DPP pela Instrução Normativa nº 1.681. A declaração segue os padrões e patamares econômicos da União Europeia por ser um dos instrumentos que colocará em prática o Plano de Ação sobre Erosão da Base Tributária e Transferência de Lucros (BEPS), desenvolvido pela Organização para a Cooperação e Desenvolvimento Económico ou Econômico (OCDE) para aumentar a transparência fiscal e evitar “estruturas agressivas ou abusivas”, algumas inclusive teriam o objetivo de financiar o terrorismo.

Fonte: Valor Econômico
Data: 28 de julho de 2017
Acesso: 28 de julho de 2017

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  119. Greetings! I know this is kinda off topic however I’d figured I’d ask. Would you be interested in trading links or maybe guest writing a blog article or vice-versa? My blog goes over a lot of the same subjects as yours and I think we could greatly benefit from each other. If you are interested feel free to send me an email. I look forward to hearing from you! Wonderful blog by the way!|

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