Seu arquivo foi entregue corretamente? Cuidado, você pode emitir informações sem saber.
Frequentemente o fisco cria novas declarações para a entrega do SPED pelo contribuinte, e na maioria das vezes o início da obrigatoriedade do envio nem sempre é suficiente para a correta adequação e implantação dos recursos necessários para o empresário ou a entidade contábil gerar as informações.
A consequência, é a entrega da declaração incompleta e passível de erros. Para isso é importante ressaltar que existem dois tipos de erros:
- O Programa Validador e Assinador (PVA) do SPED acusa erros em relação a estrutura e layout do arquivo, que se não for sanado, impossibilita a transmissão ao fisco. A informação deve ser prestada sempre que houver ocorrido alguma operação, porém, mesmo sendo omitida, o PVA não gera erro no momento da validação.
-
Mas como transmitir um SPED sem uma informação obrigatória?
- Isso é possível, pois o PVA bloqueia apenas as inconsistências que são aplicadas como regra geral para as empresas, ou seja, campos obrigatórios independente do tipo de sociedade ou movimentações. Os casos específicos ficam a cargo de cada uma verificar se a informação é obrigatória ou não (enfoque do declarante), por isso, muitas vezes, existe a falsa ilusão que uma vez o arquivo validado pelo PVA, ele está completamente correto.
- Por exemplo: Levando em consideração a Escrituração Fiscal Digital (EFD) ICMS/IPI, através do guia prático Versão 2.0.22, atualizado em 11/12/2017, é possível encontrar diversos casos em que determinado registro é obrigatório, porém se não informado, o PVA não impede o envio da declaração.
- Um desses casos é o registro C500, no qual são informadas as despesas/saídas com energia elétrica, água canalizada e gás, que não geram erros, porém a empresa é obrigada a informar caso tenha ocorrido o fato no mês do arquivo apresentado.
-
Cada SPED possui um manual orientando quais são os registros existentes e exigidos
- Geralmente essas informações são abreviadas por siglas. Vejamos o que dispõe o manual do EFD ICMS/IPI:
- Capítulo II – Informações para geração dos arquivos da EFD-ICMS/IPI
Seção 2 – Registros a serem apresentados – Perfil do informante Observações:Se especificado “O” na coluna de obrigatoriedade, significa que o registro deve ser sempre apresentado.
Se especificado “O (…)” na coluna de obrigatoriedade, significa que, quando ocorrer a condição estabelecida, o registro deve ser apresentado.
Se especificado “OC” na coluna de obrigatoriedade, significa que o registro deve ser apresentado sempre que houver informação a ser prestada.
Se especificado “N” na coluna de obrigatoriedade, significa que o registro não pode ser apresentado.
Importante ressaltar que, embora a obrigação seja entregue dentro do prazo legal, o fisco pode autuar as empresas que deixem de informar, ou informem uma declaração com erro. Vejamos:
-
LEI Nº 12.766, DE 27 DE DEZEMBRO DE 2012.
“Art. 57. O sujeito passivo que deixar de apresentar nos prazos fixados declaração, demonstrativo ou escrituração digital exigidos nos termos do art. 16 da Lei no 9.779, de 19 de janeiro de 1999, ou que os apresentar com incorreções ou omissões será intimado para apresentá-los ou para prestar esclarecimentos nos prazos estipulados pela Secretaria da Receita Federal do Brasil e sujeitar-se-á às seguintes multas:
III – por apresentar declaração, demonstrativo ou escrituração digital com informações inexatas, incompletas ou omitidas: 0,2% (dois décimos por cento), não inferior a R$ 100,00 (cem reais), sobre o faturamento do mês anterior ao da entrega da declaração, demonstrativo ou escrituração equivocada, assim entendido como a receita decorrente das vendas de mercadorias e serviços.”
Dependendo do porte e da movimentação da sociedade, fica inviável conferir todos os campos exigidos pelo fisco, desta forma, muitas vezes a melhor solução é o investimento de tempo e recurso financeiro, para implantação de software que dê suporte na validação dos arquivos, ou a contratação de consultoria especializada para análise dos arquivos antes da transmissão, a fim de minimizar a possibilidade de futuros questionamentos e até mesmo autuações fiscais.
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