Quem tem direito à compensação do ICMS sobre a base de cálculo PIS/Cofins conforme despacho publicado pela Procuradoria Geral da Fazenda Nacional?
O Supremo Tribunal Federal tomou uma decisão que modulou os efeitos da decisão sobre a exclusão do ICMS da base de cálculo do PIS e Contribuição para o Financiamento da Seguridade Social(Cofins), referente ao RE 574.706/PR, trazendo dúvidas aos contribuintes, onde se perguntavam se era possível utilizar o crédito imediatamente ou era necessário entrar com ação judicial para obtenção do direito do crédito.
Segundo o empresário Agamenon Vinicius Basilio da Gama, a Iha Serviços, empresa de Consultoria de Negócios, a Procuradoria Geral da Fazenda Nacional (PGFN) indicou todos os procedimentos para o cumprimento do julgamento dos ED no 574.706/PR, após isso, os contribuintes passaram a ter maior segurança jurídica para utilização dos créditos.
Entenda
“Em março de 2017, no recurso extraordinário n° 574.706, o Supremo Tribunal Federal fixou entendimento de que as contribuições podem incidir apenas sobre a parcela da receita da venda de mercadorias e da prestação de serviços, não permitindo a inclusão do ICMS na base de cálculo dessas contribuições, no qual, tal entendimento teve repercussão geral. No entanto, a decisão do STF não era o bastante para o aproveitamento dos créditos pelos contribuintes naquele momento. Era preciso esperar a modulação dos efeitos, para definir qual seria o ICMS que deveria ser excluído da base de cálculo do Pis e Cofins, visto que a Receita Federal havia entendimento contrário a decisão do STF e considerando que o ICMS a ser excluído da base de cálculo era o valor fixado pago aos Estados e não o destacado na nota fiscal”, informa Agamenon.
Ele afirma que a condição foi finalizada em 13 de maio de 2021, após o STF decidir pela modulação dos efeitos da decisão e reconhecer que o ICMS a ser excluído da base de cálculo do PIS e Cofins é o ICMS destacado da nota fiscal.
“Além de reconhecer que o valor a ser excluído era o ICMS destacado da nota fiscal, foi informado aos contribuintes que ingressaram com ações até a 15 de abril de 2017 terão o direito ao crédito do período anterior ao julgamento, entretanto, os contribuintes que não ingressaram com medida judicial ou ingressaram após a data citada, terão direito somente após esse dia. Os contribuintes que ingressaram com ação até 15 de abril de 2017, deverão continuar com a ação em andamento até que finalize o processo, onde deverão transitar em julgado. Dessa forma, o contribuinte terá direito a todo crédito do período discutido e total direito a realizar a habilitação do crédito perante a Receita Federal, além de realizar suas compensações “, afirma.
Segundo Agamenon, as empresas que possuem liminar, não necessitam aguardar o trânsito em julgado para excluir o ICMS do mês, podendo excluir o ICMS no mês de competência. É preciso aguardar somente o término da ação para compensação do montante do crédito dos períodos anteriores. Ele complementa que as empresas que ingressaram com a ação após 15 de abril de 2017, após o pronunciamento da PGFN, não haverá necessidade de discussão judicial para reaver os valores pagos do ICMS sobre a base de cálculo do PIS e Cofins, onde os contribuintes poderão realizar a compensação de forma administrativa, somente a partir de 16 de abril de 2017.
Apuração dos créditos e realização das compensações
Empresas que ingressaram com medidas judiciais, até 15 de abril de 2017 devem aguardar o trânsito em julgado, realizar a habilitação do crédito perante a Receita Federal e somente após 60 dias, prazo para para deferir ou indeferir o processo, poderá realizar as compensações através do PERD/COMP. O crédito apurado poderá ser compensado com qualquer Tributo Federal e possui atualização da Selic.
A apuração do cálculo deverá identificar o ICMS destacado da nota fiscal de todo período em questão, referente aos produtos ou serviços que serviram de base de cálculo para o PIS e Cofins, aplicando a alíquota correspondente ao regime do contribuinte, sendo lucro presumido ou real.
“É importante estar atento ao regime de lucro real (não-cumulativo), no qual, ainda pode ser discutido se o ICMS destacado na aquisição da mercadoria é custo ou não para obtenção do crédito, uma discussão que já existe no âmbito do IRPJ e CSLL. Para demonstrar tais créditos no EFD Contribuições, devem ser obedecidas as regras definidas a partir de janeiro de 2019, quando nasceu a exigência do registro 1050, na versão 3.1.10 da EFD-Contribuições, que tem a finalidade de detalhar os ajustes do bloco M (apuração). O mais importante é se atentar no acompanhamento das mudanças sobre o assunto, tendo em vista que, ainda haverá alguns pronunciamentos, instruções, por parte da Receita Federal”, diz Agamenon.
Agamenon alerta os profissionais de contabilidade e jurídico, que devem ter total condições de atendimento às demandas de empresas que possam surgir, pois é preciso estar preparado para empreender nesse mercado, atendendo as necessidades das empresas.
“É importante a transformação dos empresários responsáveis pelas empresas jurídicas e contáveis, eles devem se atualizar. É preciso “mudar a chave”, o olhar, a forma de enxergar as questões e procedimentos financeiros e tributários de seus clientes, para que possam acompanhar as evoluções dos negócios e continuar prosperando. Buscar o conhecimento é o ideal para o crescimento e sucesso de qualquer negócio”, finaliza.
Serviço
Ilha Serviços – Consultoria em Negócios
Site: ilha-servicos.negocio.site
Instagram: @ilha.servicos
Facebook: @ilha.servicos/
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dass Sie einerseits genügend Halt und andererseits ausreichend Bewegungsfreiheit haben,
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Zudem sind sie leichter und flexibler handhabbar. Wer seinen Rollstuhl speziell für die Wohnung braucht, braucht durch
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Das alles gilt seit dem 4. Januar. Eigentlich hatten die Hersteller
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Unbedenklichkeit benötigen Zeit und Geld. Tattoos gehen nach der jetzigen Verordnung eigentlich nur noch in Schwarz, Grau oder Weiß?
Diese müssen registriert werden, die Unbedenklichkeit also nachgewiesen werden. Das sind im Wesentlichen die Farben,
die als unbedenklich übriggeblieben sind, da hier keine entsprechenden Farbpigmente enthalten sind, denn häufig sind es ja gerade die Farbpigmente, die als problembehaftet gelten. Die Untersuchung und Registrierung neuer Farben wird sicherlich ein längerer
Prozess. Ich denke aber, dass Hersteller ein hohes Interesse daran haben, das für die Farben nachzuholen, bzw.
auch neue Farben zu entwickeln. Aus allergologischer Sicht
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Die Verbindung, welche die Haut mit der Tatowierung eingeht,
besteht nicht nur auf der Oberflache des Korpers,
sondern geht viel tiefer in diesen hinein. Die Haut spielt eine bedeutende Rolle und ist daher aus einer anderen Perspektive zu
betrachten, als nur die eines bloBen Tragers der Tatowierung und einer Hulle des Korpers.
In diesem Kapitel untersuche ich die gegenwartige westliche Hautvorstellung, die Wahrnehmung des Korperbildes und
die Bedeutung der Haut fur die Tatowierung. Das vorherrschende kollektive Korperbild in Europa hat sich seit
der cartesianischen Spaltung in Leib und Seele, Geist und
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gilt als gegeben und unwandelbar. Dieses leibesphilosophische Denken, welches der
Kultur den Geist und der Natur den Korper zuschreibt, begreift sich selbst als auBerhalb der Geschichte stehend.
Sie markiert als Grenze das Innen und AuBen. Die Haut ist eng verknupft mit der
Leibeswahrnehmung. Zwar wandelte sich die Leibeswahrnehmung im 18.
Jahrhundert mit den Anfangen der Anatomie, denn das geheimnisvolle Dahinterliegende wurde sichtbar gemacht.
Doch dem kollektiven Korperbild entsprechend, dient die Haut noch immer zur
Begrenzung des Korpers (Benthien, 1999, S. 1517).
Dieses Korperbild wurde durch das subjektbezogene Denken besonders gefordert, welches
das menschliche Zentrum im Inneren des Korpers sieht (Benthien,
1999, S.11-12).
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Cega gebaut. Allerdings kann man diese Sehenswürdigkeit und die angeschlossenen Gärten nur in den Sommermonaten besichtigen. Von November bis Februar ist die Anlage geschlossen. Weitere lohnende Ausflugsziele in der Runde Cala Ratjada sind das Castell Capdepera, eine Festung aus dem 14.
Jahrhundert über der Stadt und der Leuchtturm
Far de Capdepera. Von hier hat man bei klarem Wetter einen atemberaubenden Blick bis Menorca haben, oder den romantischen Sonnenuntergang genießen kann.
Apropos Menorca, vom Hafen in Cala Ratjada aus starten Fähren von Mallorca nach Menorca.
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