O trabalho das empresas pode aumentar com mudanças no ISS

O trabalho das empresas pode aumentar com mudanças no ISS

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A reforma do ISS está pronta para ser votada no Senado

O imposto municipal poderá ser recolhido com base no domicílio do tomador do serviço, o que aumentaria as obrigações acessórias das empresas

A reforma do Imposto sobre Serviços de Qualquer Natureza (ISS) está pronta para ser votada no Senado. A proposta tem dois objetivos claros: combater a guerra fiscal entre prefeituras e melhorar o reparte do imposto entre os municípios. É aqui que as coisas começam a se complicar.

Para equilibrar o reparte, em alguns casos, o recolhimento do ISS levará em conta o domicílio do tomador do serviço. Ou seja, o imposto não vai ficar necessariamente no município onde o serviço foi prestado, mas onde reside quem o contratou.

Isso vai valer para prestação de serviços de planos e convênios de saúde, odontológico e hospitalar, corretagem, agenciamento, arrendamento, leasing, entre outros, dentre os quais, serviços prestados pela administradora de cartão de crédito ou débito.

Claro que vai sobrar para as empresas o ônus da redistribuição do imposto. O empresário, que antes se preocupava apenas com as regras tributárias do local onde estava instalado, terá de se adequar às minúcias das legislações do ISS de todos dos municípios do país.

Não é exatamente uma novidade essa prática do fisco de jogar mais obrigações sobre os ombros dos contribuintes. Foi assim que aconteceu recentemente com o ICMS interestadual. “A burocracia e o ônus dessa regra ficarão com as empresas, que terão de se enfronhar em uma série de normas tributárias”, diz o tributarista Maucir Fregonesi Jr, sócio do escritório Siqueira Castro Advogados.

Para Fregonesi Jr, o fisco teria total condição de saber por conta própria o domicílio do tomador do serviço e organizar o reparte do ISS. “A reforma do imposto é necessária, mas sempre buscando a simplificação, o que não é o caso”, diz Fregonesi Jr.

TRAMITAÇÃO

Essa mudança é prevista no substitutivo ao Projeto de Lei do Senado (PLS) 386, de 2012, que está na pauta de votação desde o dia 2 de outubro. O texto já foi aprovado pela Câmara e agora precisa ser votado, em definitivo, pelos senadores, o que pode acontecer na próxima quarta-feira (10/08).

O projeto também inclui novas categorias de atividades entre aquelas passíveis de serem tributadas pelo ISS, como aplicação de tatuagens e piercings, vigilância e monitoramento de bens móveis, corte de árvores, lavagem, secagem, entre vários outros.

Nessa lista entram também os serviços de disponibilização de conteúdos de áudio, vídeo, imagem e texto por meio da internet. Aqui estariam atividades como as do Netflix, que hoje não pagam ISS.

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Esse é um dos pontos mais polêmicos do projeto, afinal, tributar o Netflix abriria espaço para a tributação de serviços semelhantes, como os conteúdos do YouTube, Facebook e outros.

Para piorar, além dos municípios, os Estados também estão de olho nesses conteúdos da internet. Os governadores dizem que estes são serviços de comunicação, os quais já incide o ICMS, não o ISS.

“O argumento deles é que quem recebe o serviço pode interferir no conteúdo, pausando um filme no Netflix, por exemplo, o que configuraria um processo de comunicação”, diz a advogada Maria Leonor Leite Vieira, que preside o Instituto de Direito Empresarial Geraldo Ataliba.

Para a advogada, o Supremo Tribunal Federal (STF) terá de pacificar a questão, chegando a um entendimento sobre quem tem o direito de tributar esse tipo de serviço, se estados ou municípios.

É PROIBIDO FAZER GUERRA

O PLS 386 traz regras que buscam acabar definitivamente com a guerra fiscal do ISS, imposto que sempre foi usado pelos municípios como instrumento de atração de investimento. A proposta que está no Senado reforça que a alíquota mínima do imposto deve ser de 2%, algo que já consta da Lei Complementar 116, de 2003, que traz as regras para esse imposto municipal.

Mas o texto do PLS vai além, impondo que o ISS não poderá ser objeto de concessão de isenções, incentivos ou benefícios fiscais e financeiros. Também não poderá ter a base de cálculo reduzida.

“A alíquota mínima de 2% e a máxima de 5% já são fixadas na Lei Complementar. O problema é que os municípios fazem leis ordinárias mudando suas bases de cálculo. Claro que isso é irregular, mas esse julgamento é feito pelo STF, o que geralmente leva muito tempo” diz Maria Leonor, que considera positivas as proibições trazidas pelo PLS 386.

O projeto também melhora outro ponto da Lei Complementar 116: a cobrança do ISS no caso de exportações de serviços. Em geral, pelo texto da lei, o imposto não pode ser cobrado nas exportações, exceto quando o resultado do serviço é verificado no Brasil.

“O que seria ‘resultado do serviço’? O resultado de serviços de pesquisas laboratoriais prestados lá fora, por exemplo, podem retornar indiretamente ao país. Caberia a cobrança do ISS nesse caso?”, questiona Maucir Fregonesi Jr.

O PLS aperfeiçoa esse ponto da redação, incluindo que a cobrança do ISS ocorra nas exportações quando há ingresso de divisas ao País, ou seja, atrela o resultado do serviço prestado no exterior a um retorno financeiro para a empresa que está no Brasil.

Fonte: Fenacon
Data:  08 de agosto de 2016
Acesso: 12 de agosto de 2016

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