Tax Consulting

Diagnosis and tax planning

Technical inquiries related to direct and indirect taxes

Survey of federal tax credits

ICMS and ICMS-ST recovery

Identification and quantification of the benefits of the Lei do Bem (technological innovation)

Tax/Corporate Planning

Calculation of Transfer Prices

Technical reports to support administrative and judicial discussions

PIS/COFINS and ICMS Credit Recovery

LAST 5 YEARS

Submission of requested information (calculations, trial balances, etc.)

CLIENT

Analysis of information and presentation of opportunities

MCS MARKUP

Decision making about the credits that will be used (risk/return)

CLIENT

Corrections and compensations, based on the customer's decision.

MCS MARKUP

We identify and measure the benefits, present the technical basis and, subsequently, carry out all the necessary corrections to implement the opportunities.

ICMS calculation based on PIS/COFINS

We can perform the following jobs:

  • Preparation of calculations based on ICMS highlighted in the note / Solution COSIT 13/08;

  • Update of the tax overdue;

  • Preparation of book to document support requests for credit approval with the Federal Revenue;

  • Assessment of tax impacts arising from the accounting recognition of the credit.

IRPJ/CSLL

Fiscal diagnosis in order to identify opportunities to reduce the tax burden.


Application: companies that have IRPJ/CSLL expense in the last 5 years.

Examples:


Attention to companies in real profit that:


Have tax benefits (PAT, exploration profit incentive - SUDAM and SUDENE region, etc.);


They determine transfer price adjustments (operations with related companies abroad / located in tax havens);


Have PDD (tax analysis);


Have tax incentives related to ICMS (subsidy);


Have tax balances to be recovered, without realization.

IRPJ/CSLL

Corporate restructuring
Review/Development of federal accessory obligations (ECD, ECF, EFD-Contributions)
Tax package (USGAAP revision)
Calculation of Transfer Prices
Changes in taxation regimes - Presumed to Real or vice versa

Examples:


Spin-off, incorporation and their tax impacts;


Review / completion of Digital Accounting Bookkeeping (ECD), using electronic tools;


Review / completion of the Fiscal Accounting Bookkeeping (ECF), using electronic tools;


Support to the IT area and other departments involved in the extraction/manipulation of data in relation to tax matters, seeking to clarify doubts that may arise during the process of generating and implementing the ECF file;


Crossing between ancillary obligations (ECF x ECD x SPED Fiscal x DCTF);
Review or completion of reports in USGAAP / IFRS Tax Package (accrual to actual).

ICMS/ICMS-ST

Special regimes: Calculation, protocol and monitoring;
ICMS-ST reimbursement;
Survey of opportunities;
Tax Review;
Compliance with tax obligations; and
Tax parameterization, preparation of the tax book and exception rules

Examples:

CAT Ordinance No. 108/2013: Regulates the granting of a special regime for the suspension of ICMS assessment due on customs clearance of imported goods that will be subject to interstate exits subject to a 4% rate, pursuant to Federal Senate Resolution 13/2012;


CAT Ordinance No. 42/2018: Establishes discipline for the complement and reimbursement of the tax withheld by passive subjection by replacement or anticipated and provides for related procedures.

ICMS

Accumulated Credit

Analysis of applicable legislation and possibilities of use;
Credit balance validation;
Registration of the request via SEFAZ;
Monitoring and recognition in the tax account;
Intermediation of the acquisition or sale of the credit balance.

We have vast experience and applied technology to compose the digital files for calculating the accumulated credit, both in the simplified calculation system and in the calculation of the amount by applying the costing methodology. In addition to the specific system implemented by SEFAZ/SP, our team has already carried out restoration work for the states of Rio de Janeiro, Paraná, Espírito Santo and Brasília.


Related works:

 

  • Validation of the ICMS credit balance: Analysis of the nature and quality of the accumulated balance, avoiding possible questions from the tax authorities regarding its origin and use;

  • Intermediation of the acquisition or sale of the ICMS credit balance: Assistance in monetizing the accumulated balance or in its acquisition.