União recria taxa derrubada pelo Supremo

União recria taxa derrubada pelo Supremo

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Por Joice Bacelo | De São Paulo

Empresas instaladas na Zona Franca de Manaus terão mais custos com a importação de mercadorias a partir do ano que vem. Isso por conta de duas taxas recém criadas pelo governo federal ­ cuja arrecadação será destinada exclusivamente ao custeio da Superintendência da Zona Franca de Manaus (Suframa). Uma delas será cobrada pelos serviços prestados (como cadastros e atualizações) e a outra está relacionada ao controle administrativo de incentivos fiscais (TCIF).

As novas taxas foram instituídas por meio da Medida Provisória (MP) nº 757, publicada ontem no Diário Oficial da União. A cobrança começará a ser efetuada após 90 dias da data de publicação. Estarão sujeitas ao recolhimento todas as empresas ou entidades equiparadas (como consórcios) que se utilizarem dos serviços ou solicitarem o licenciamento de importação ou registro de procolo de ingresso de mercadorias.

Segundo especialistas, o que o governo fez, de forma mais precisa, foi corrigir uma norma anterior ­ que instituiu a chamada Taxa de Serviços Administrativos (TSA). Essa taxa, a TSA, deixou de ser recolhida por grande parte dos contribuintes. Isso porque o parágrafo 1º da Lei nº 9.960/2000, que instituiu a cobrança, foi considerado inconstitucional pelo Supremo Tribunal Federal (STF) em um julgamento com repercussão geral em maio deste ano. Os ministros entenderam que a norma não definia de forma específica o fato gerador da cobrança.

“O texto era completamente genérico”, diz o advogado Rafael Capaz Goulart, do escritório Abreu Faria, Goulart & Santos Advogados. “O governo está, agora, restabelecendo a taxa, mas com uma outra roupagem. Foi feito todo um detalhamento para que não incorresse no mesmo erro da TSA”, acrescenta.

O tributarista Eduardo Winters Costa, do Salusse Marangoni Advogados, chama a atenção, no entanto, que os valores estabelecidos por meio da MP são mais altos do que os relacionados na TSA, que eram fixados por portaria da Suframa. Os decorrentes dos serviços, por exemplo -­ que agora estão discriminados em uma tabela anexa -­ tiveram aumento considerável: a taxa cobrada para cadastros, que era de R$ 40, passará para R$ 140 e a reativação cadastral, de R$ 100, aumentará para R$ 173.

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A mudança mais pesada, porém, diz a respeito à taxa relacionada ao controle administrativo de incentivos fiscais (TCIF). Essa cobrança é exigida pelo exercício regular do poder de polícia (fiscalização) da Suframa. Os valores, antes, estavam fixados em uma tabela progressiva: para mercadorias de até R$ 1 mil recolhia­-se R$ 3; entre R$ 30 mil a R$ 35 mil era cobrada uma taxa de R$ 314; já para mercadorias que somavam entre R$ 400 mil e R$ 450 mil o pagamento era de R$ 4 mil. “A taxa estava, em média, abaixo de 1% do valor total das mercadorias”, destaca Eduardo Costa.

Já a medida provisória estabelece aos pedidos de licenciamento de importação ou por cada nota incluída em registro de protocolo de ingresso de mercadorias taxa de até 1,5% do valor total dos produtos (com mínimo de R$ 200). E determina ainda o recolhimento de R$ 30 por cada item constante desse pedido ou nota.

“Pode chegar a altos valores e, inclusive, muito elevados para uma fiscalização de importação”, destaca o advogado Maucir Fregonesi Júnior, sócio do setor tributário do escritório Siqueira Castro. Sobretudo, diz, nos casos de produtos de alto valor agregado, que não demandam, necessariamente, de uma estrutura de fiscalização complexa para a liberação da mercadoria.

“Existe uma situação crítica de disponibilidade de recursos na região. Nós sabemos disso. Mas não se pode ter uma situação de cobrança desproporcional ao tipo de serviço prestado”, pondera.

De acordo com a MP, ficarão isentos do pagamento da TCIF o microempreendedor individual e as micro e pequenas empresas sujeitas ao Simples Nacional, entre outros. Mercadorias que ingressarem na Zona Franca para industrialização e posterior exportação contarão com a suspensão da taxa ­ que se converterá em isenção no momento da efetiva saída dos produtos do território nacional. Os valores da TCIF serão ainda reduzidos em 20% para os bens de informática, seus insumos e componentes.

Além da MP 757, o governo publicou outras quatro medidas provisórias ­ a de número 755 trata do repasse do Fundo Penitenciário Nacional e a 754 de normas para a regulação do setor farmacêutico.

Fonte: Valor Econômico
Data: 21 de dezembro de 2016
Acesso: 23 de dezembro de 2016

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