Fisco limita uso de créditos de PIS e Cofins de frete

Fisco limita uso de créditos de PIS e Cofins de frete

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Uma indústria tributada pelo regime monofásico não tem direito a créditos de PIS e Cofins decorrentes do frete pago no transporte de mercadorias para revenda, realizado entre estabelecimentos do mesmo grupo econômico.

Só há exceção se a fabricante adquirir essas mercadorias de outra importadora ou produtora. Com o entendimento, a Receita Federal unificou sua interpretação sobre o tema por meio da Solução de Divergência da Coordenação-Geral de Tributação (Cosit) nº 2.

São tributados pelo regime monofásico os segmentos de combustíveis, pneus, cosméticos, bebidas e medicamentos, por exemplo. Na tributação monofásica, a cobrança do PIS e da Cofins é concentrada no primeiro elo da cadeia produtiva – no fabricante ou importador.

Segundo o advogado Thiago Garbelotti, do Braga & Moreno Consultores e Advogados, como no regime monofásico o tributo já foi recolhido, o Fisco alega que não haveria direito ao crédito na revenda. Para o tributarista, porém, o sistema monofásico não entra em conflito com o regime da não cumulatividade do PIS e da Cofins, que dá direito a créditos em cada fase da cadeia. “E não há fundamento legal que impeça o aproveitamento desses créditos”, diz.

O tema já foi discutido no Conselho Administrativo de recursos Fiscais (Carf), mas não há decisão da Câmara Superior para uniformizar a questão ainda. “Há decisões de câmaras comuns em sentidos diversos”, diz Garbelotti.

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Em 2016, a Idaza Distribuidora de Petróleo venceu discussão sobre o tema no Carf. A 2ª Turma da 3ª Câmara permitiu o desconto de créditos da não cumulatividade “vinculados à receita auferida pelo distribuidor ou varejista na venda de combustíveis sujeitos ao regime monofásico, observados os limites e restrições legais.”

Segundo o advogado Geraldo Valentim, do MVA Advogados, com a solução de divergência fica definido entre os fiscais como tratar o uso desses créditos.

Pela Lei 10.833, a empresa pode descontar créditos de PIS e Cofins dos tributos a pagar em relação a gastos com armazenagem de mercadorias e frete na operação de venda de bens e serviços, quando o ônus é do vendedor. A Receita faz a interpretação literal da norma.

De acordo com Valentim, é importante observar a solução de divergência porque os fiscais baseiam-se nelas para realizar novas fiscalizações. “A Receita tem lavrado autos de infração que abrangem, inclusive, o período passado, o que é vedado pela IN 1.396, da própria Receita”, diz.

Por Laura Ignacio | De São Paulo

Fonte: Valor Econômico
Data: 31 de janeiro de 2017
Acesso: 03 de fevereiro de 2017

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