Lucro Real e Despesas Operacionais Não Dedutíveis

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São despesas operacionais não dedutíveis, para efeito de apuração do  conforme a legislação (Lei 9.249/1995, e IN SRF nº 11/1996) as despesas:

a) de qualquer provisão, com exceção apenas daquelas constituídas para:  de empregados e 13º salário; reservas técnicas das companhias de seguro e de capitalização, bem como das entidades de previdência privada cuja constituição é exigida pela legislação especial a elas aplicável;

b) das contraprestações de arrendamento mercantil e do aluguel de bens móveis ou imóveis, exceto quando relacionados intrinsecamente com a produção ou comercialização dos bens e serviços;

c) de despesas de  amortização, manutenção, reparo, conservação, impostos, taxas, seguros e quaisquer outros gastos com bens móveis e imóveis, exceto se relacionados intrinsecamente com a produção ou comercialização (sobre o conceito de bem intrinsecamente relacionado com a produção ou comercialização vide IN SRF nº 11/96, art. 25);

d) das despesas com alimentação de sócios, acionistas e administradores;

e) das contribuições não compulsórias, exceto as destinadas a custear seguros e planos de saúde e benefícios complementares assemelhados aos da Previdência Social, instituídos em favor de empregados e dirigentes da pessoa jurídica;

f) de doações, exceto se efetuadas em favor: do PRONAC; instituições de ensino e pesquisa sem finalidade lucrativa (limitada a 1,5% do lucro operacional); de entidades civis sem fins lucrativos legalmente constituídas no Brasil que prestem serviços em benefício de empregados da pessoa jurídica (limitada a 2% do lucro operacional);

g) das despesas com brindes.

A Contribuição Social sobre o Lucro não mais é considerada como despesa dedutível para fins da apuração do  devendo o respectivo valor ser adicionado ao lucro líquido.

FGV (2021):

QUESTÃO CERTA: Na apuração do imposto sobre a renda pelo lucro real de uma sociedade empresária, são despesas não dedutíveis as relativas

Alternativas

A) à alimentação fornecida aos empregados.

B) aos seguros e planos de saúde dos empregados.

C) às multas administrativas e por infrações fiscais de empregados. 

D) à formação profissional de empregados.

E) às contribuições não compulsórias destinadas a custear planos de benefícios complementares em benefício dos empregados.  

O lucro real é um dos regimes jurídicos para apuração do imposto de renda ao qual as pessoas jurídicas estão sujeitas. Consiste no lucro líquido do período ajustado por adições, exclusões e compensações.

  • Adições: aumentam a base do imposto
  • Deduções: diminuem a base de cálculo

Dessa forma, no caso das multas, na demonstração do resultado, elas reduziriam o valor do lucro e por consequência o valor do imposto que será apurado. Por isso elas não são dedutíveis, pois uma vez permitido, seria como “passar a mão na cabeça” de quem fez coisa errada.

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