Receita exige mais dados para consultas

Receita exige mais dados para consultas

Por |

Empresas brasileiras que quiserem abrir processo de consulta sobre tributação internacional à Receita Federal passam a ter que fornecer mais dados sobre sua estrutura societária global. Por meio da Instrução Normativa (IN) nº 1.689, o órgão passou a exigir novos requisitos para emitir soluções de consulta.

A mudança faz parte da implantação do Plano de Ação sobre Erosão da Base Tributária e Transferência de Lucros (Beps) no Brasil, o que permitirá uma maior troca de informações entre os Fiscos do mundo todo.

Coordenado pela Organização para Cooperação e Desenvolvimento Econômico (OCDE) o objetivo do Beps é implantar medidas globais de combate à evasão e elisão fiscal, pela transferência artificial de lucros para países com baixa tributação.

De acordo com a IN, será necessário obedecer os novos critérios se o tema da consulta abranger preços de transferência (regras aplicadas na importação entre partes vinculadas), o Programa de Apoio ao Desenvolvimento Tecnológico da Indústria de Semicondutores – Padis (de incentivo à produção nacional de dispositivos eletrônicos como displays) e estabelecimento permanente (escritório informal de empresa que atua em outro país, sem estar constituída nele).

“Haverá a necessidade de a empresa identificar o controlador (direto e final) e o país de residência da matriz, do estabelecimento permanente e de todas as partes relacionadas com as quais o contribuinte efetue as transações objeto da consulta”, afirma Geraldo Valentim, do MVA Advogados.

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Segundo nota divulgada pela Receita, uma das exigências do Beps é a troca de informações entre os Fiscos sobre as orientações que emitem para empresas que fazem transações internacionais sob padrões mínimos.

Para Valentim, o Beps é apenas a justificativa. “A medida permitirá maior cruzamento de informações também para fins fiscalizatórios no país”, diz. O advogado lembra que em razão do Decreto nº 8.842, de 2016, o Brasil trocará dados fiscais com mais de cem países e jurisdições. “Isso permitirá inclusive a cobrança de crédito tributário devido de um país para outro.”

Essa não é a primeira norma criada pela Receita para adaptação ao Beps. “A IN nº 1.681, de 2016, que criou a Declaração País-a-País (DPP) também já está em vigor. E muitas outras devem ser editadas”, afirma Alexandre Siciliano, do Lobo & De Rizzo Advogados. Ele alerta que a nova norma tem efeito retroativo.

O texto da IN 1.689 já havia sido divulgado para consulta pública. “Contudo, nesse caso, o texto final ficou igual ao publicado para debate. Nenhuma sugestão foi acatada”, afirma Siciliano, que participa de associações que propõem mudanças.

Por Laura Ignacio | De São Paulo

Fonte: Valor Econômico 
Data: 22 de fevereiro de 2017
Acesso: 24 de fevereiro de 2017

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