Receita Federal regulamenta parcelamento de débitos

Receita Federal regulamenta parcelamento de débitos

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Empresas e pessoas físicas já podem aderir ao Programa de Regularização Tributária (PRT). A Receita Federal publicou ontem a regulamentação do parcelamento, apelidado de “novo Refis”, na qual detalha como os contribuintes poderão usar, por exemplo, os créditos para pagar os débitos vencidos até 30 de novembro de 2016. A adesão permitirá que os contribuintes obtenham certidão positiva de débito, com efeitos de negativa, necessária para a participação em licitações e empréstimos.

Em entrevista coletiva sobre a Instrução Normativa da Receita Federal nº 1.687, publicada ontem no Diário Oficial da União, o secretário da Receita, Jorge Rachid, mantém a previsão de arrecadar R$ 10 bilhões com o programa. O governo acredita que a medida ajudará a retomada da economia.

Os benefícios do PRT, como a possibilidade de uso de base negativa da CSLL e prejuízo fiscal para quitar dívida com o Fisco, são sedutoras segundo advogados. Contudo, os profissionais aconselham as companhias a avaliar se conseguirão cumprir os requisitos do programa, também listados na regulamentação. A adesão ao PRT implica a inclusão automática no programa de todos os débitos abertos e exige a regularidade fiscal.

Por esse motivo, segundo o advogado tributarista Roberto Goldstajn, o parcelamento é interessante desde que as empresas estejam estruturadas para tanto. “A companhia precisará honrar os tributos tributários e previdenciários, o que inclui o FGTS, durante todo o período em que estiver no parcelamento”, afirma.

Goldstajn recomenda às companhias interessadas a adoção de um programa de integridade tributária. “Uma medida cautelar fiscal ou a decretação de falência excluem a companhia do programa”, diz o advogado. Nesse caso, são restabelecidos os valores originais dos débitos. “E se a empresa chegou a desistir de processo para incluir o débito no PRT, não poderá ressuscitar a discussão administrativa ou judicial”, afirma.

Quem decidir incluir esses débitos no programa, deverá apresentar comprovante do pedido de desistência da discussão admi nistrativa ou judicial na Receita até o dia 31 de maio, prazo máximo para adesão ao programa. Esses contribuintes, porém, deverão aguardar a regulamentação do PRT pela Procuradoria-Geral da Fazenda Nacional (PGFN). Segundo o órgão, a norma deverá ser publicada na sexta-feira.

Se os contribuintes usarem prejuízo fiscal ou base negativa de CSLL, não poderão sacar o depósito judicial relativo à disputa com o Fisco, segundo explicou o subsecretário de tributação da Receita, Carlos Roberto Occaso, na coletiva de imprensa. De acordo com ele, o saldo nessa conta será usado para abater a dívida e com a sobra será feito o cálculo do parcelamento e do uso dos créditos. No caso de empresas que tiverem débitos após 30 de novembro de 2016 e perderem a disputa judicial, o contribuinte terá que regularizar o passivo para não perder o direito de se manter no PRT.

Para o advogado Diego Aubin Miguita, do Vaz, Barreto Shingaki & Oioli Advogados, a regulamentação deixou algumas brechas e é omissa, por exemplo, sobre a possibilidade de levantamento de depósito judicial. “Essa medida é possível de acordo com o artigo 6º, parágrafo 2º, da MP 766, que instituiu o PRT”, afirma.

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Para o tributarista, a instrução poderá ser questionada no Judiciário. “Com base na MP, o sujeito passivo pode optar pela quitação da parcela mínima em espécie, usar créditos de prejuízo fiscal ou base negativa da CSLL e outros créditos tributários para quitar débitos em discussão judicial e levantar o saldo do depósito”, acrescenta.

Occaso explicou ainda que, caso o Congresso não aprove a Medida Provisória nº 766, que instituiu o PRT no início do ano, os efeitos da norma terão que ser regulamentados por decreto presidencial. Normalmente o procedimento tem sido considerar válido os atos no período, mantendo os parcelamentos e os mecanismos definidos durante a vigência da norma.

Já o advogado Douglas Campanini, da Athros Consultoria e Auditoria, destaca que a IN esclarece quais créditos tributários poderão ser usados no PRT. “Todos os solicitados por meio do programa de compensação PerdComp até a data de prestação das informações para a consolidação no parcelamento”, afirma.

Segundo a regulamentação, o requerimento de adesão só terá efeito a partir do pagamento à vista ou da primeira prestação, cujo valor não pode ser inferior a R$ 200,00, no caso da pessoa física, e a R$ 1 mil na pessoa jurídica. Conforme Rachid, a consolidação dos débitos – quando a Receita calcula o valor renegociado – acontecerá em outubro. Mas o secretário explicou que eventual diferença entre o valor informado originalmente e o efetivo calculado será incorporada às parcelas subsequentes.

Poderá ser feito pagamento à vista em espécie de, no mínimo, de 20% do valor da dívida consolidada, e a liquidação do restante com prejuízo fiscal e base de cálculo negativa da CSLL, ou com outros créditos tributários próprios. Outra opção para o acerto de contas é o pagamento em espécie de, no mínimo, 24% da dívida consolidada em 24 prestações mensais e sucessivas, e liquidação do restante também com prejuízo fiscal e base de cálculo negativa da CSLL ou com outros créditos tributários.

Também está prevista a opção de pagamento à vista e em espécie de 20% do valor da dívida consolidada, e parcelamento do restante em até 96 prestações mensais e sucessivas. Ou em até 120 prestações calculadas observando-se os percentuais mínimos.

Caso haja saldo remanescente após a amortização com créditos, ele poderá ser parcelado em até 60 prestações adicionais.

Por Fabio Graner, Edna Simão, Beatriz Olivon e Laura Ignacio | Brasília e São Paulo

Fonte: Valor Econômico
Data: 02 de fevereiro de 2017
Acesso: 03 de fevereiro de 2017

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