PIS e COFINS Cumulativo e Não Cumulativo

Por
Pedro Santos
-
577
4629
  • PIS Cumulativo: 0,65% (Lucro presumido)
  • PIS não-cumulativo: 1,65% (Lucro real)
  • Cofins Cumulativa: 3% (Lucro presumido)
  • Cofins não-cumulativa: 7,6% (Lucro real).

1) Regime de Incidência Cumulativa

A base de cálculo é a receita operacional bruta da pessoa jurídica, sem deduções em relação a custos, despesas e encargos. Nesse regime, as alíquotas da Contribuição para o PIS/PASEP e da COFINS são, respectivamente, de 0,65% e de 3%.

As pessoas jurídicas de direito privado, e as que lhe são equiparadas pela legislação do imposto de renda, que apuram o IRPJ com base no LUCRO PRESUMIDO ou arbitrado estão sujeitas à incidência cumulativa.

As pessoas jurídicas, ainda que sujeitas á incidência não cumulativa, submetem à incidência cumulativa as receitas elencadas no artigo 10, da .

2) Regime de Incidência Não Cumulativa

Os regimes de incidência da Contribuição para o PIS/PASEP e da COFINS foram instituídos em dezembro de 2002 e fevereiro de 2004, respectivamente. O diploma legal da Contribuição para o PIS/PASEP não cumulativa é a , e o da COFINS a Lei 10.833/2003. Neste regime é permitido o desconto de créditos apurados com base em custos, despesas e encargos da pessoa jurídica. Nesse regime, as alíquotas da Contribuição para o PIS/PASEP e da COFINS são, respectivamente, de 1,65% e de 7,6%.

As pessoas jurídicas de direito privado, e as que lhe são equiparadas pela legislação do imposto de renda, que apuram o IRPJ com base no  LUCRO REAL estão sujeitas à incidência não cumulativa, exceto: as instituições financeiras, as cooperativas de crédito, as pessoas jurídicas que tenham por objeto a securitização de créditos imobiliários e financeiros, as operadoras de planos de assistência à saúde, as empresas particulares que exploram serviços de vigilância e de transporte de valores de que trata a Lei 7.102/1983, e as  (exceto as sociedades cooperativas de produção agropecuária e as sociedades cooperativas de consumo).

Fonte: http://www.portaltributario.com.br/artigos/pis-cofins-regimes.htm#:~:text=Neste%20regime%20%C3%A9%20permitido%20o,e%20de%207%2C6%25.

CEBRASPE (2023);

QUESTÃO ERRADA: A não cumulatividade das contribuições ao PIS e à COFINS opera de maneira diversa da não cumulatividade do imposto sobre produtos industrializados ([PI) e do ICMS, visto que é incompatível com a técnica da base sobre base, competindo ao legislador constitucional disciplinar o funcionamento da sistemática.

A não cumulatividade das contribuições ao PIS e à COFINS opera de maneira diversa da não cumulatividade do imposto sobre produtos industrializados ([PI) e do ICMS, visto que é incompatível com a técnica da base sobre base, competindo ao legislador constitucional disciplinar o funcionamento da sistemática.

O regime de não cumulatividade do PIS/COFINS é semelhante ao regime de não cumulatividade do IPI e do ICMS?

Resposta: NÃO!

Por quê?

NO PIS/COFINS: FACULTATIVO

a não cumulatividade da COFINS e do PIS/PASEP não é obrigatória e depende de previsão em lei, que irá definir as regras aplicáveis (artigo 195, § 12 da CF/88).

Alguns créditos são obtidos pela aplicação da alíquota da não cumulatividade sobre a despesa = método base contra base. Isso quer dizer que se aceita a dedução de créditos financeiros (como decorrentes de aluguéis pagos a PJ e as depreciações do ativo mobilizado) (JUSTIFICATIVA PARA ITEM III ESTAR ERRADO

NO IPI/ICMS: OBRIGATORIO; Não cumulatividade do ICMS e do IPI é obrigatória e baseada no texto constitucional.

Os créditos são em regra: físicos, reais e condicionais = método imposto contra imposto.

Isso quer dizer que NÃO se aceita a dedução de créditos financeiros (como decorrentes de aluguéis pagos a PJ e as depreciações do ativo mobilizado)

EXATUS (2015):

QUESTÃO CERTA: As alíquotas do PIS e da COFINS são de 0,65% e 3,00% para empresas do lucro presumido.

EXATUS (2015):

QUESTÃO CERTA: O princípio da não cumulatividade do PIS e da COFINS incide para as empresas tributadas pelo Lucro Real.

CEBRASPE (2013):

QUESTÃO ERRADA: Com base na legislação tributária, julgue os seguintes itens. A regra geral de apuração do PIS/PASEP diferencia as pessoas jurídicas tributadas com base no lucro presumido e no lucro real: no primeiro caso, a incidência é não cumulativa, ou seja, se beneficia de alíquotas menores, e, no segundo, cumulativa.

O regime não-cumulativo alcança as PJs que apuram IR com base no lucro real;

O regime cumulativo alcança as PJs que apuram o IR com base no lucro presumido.

CEBRASPE (2017):

QUESTÃO ERRADA: As contribuições para o PIS das pessoas jurídicas tributadas pelo lucro real serão retidas à alíquota de 1,65% sobre o faturamento mensal, em regime não cumulativo, enquanto que as entidades sem fins lucrativos sofrerão retenção sobre sua folha de pagamento com alíquota de 1%.

Erro: quando a questão fala que em entidades sem fins lucrativos sofrerão retenção sobre sua folha de pagamento com alíquota de 1%. Não serão retidos os valores correspondentes ao IR e às contribuições de que trata esta Instrução Normativa, nos pagamentos efetuados a: instituições de educação e de assistência social, sem fins lucrativos.

IN RFB Nº 1234, DE 11 DE JANEIRO DE 2012

DAS HIPÓTESES EM QUE NÃO HAVERÁ RETENÇÃO

Art. 4º Não serão retidos os valores correspondentes ao IR e às contribuições de que trata esta Instrução Normativa, nos pagamentos efetuados a:

III – instituições de educação e de assistência social, sem fins lucrativos, a que se refere o art. 12 da Lei nº 9.532, de 10 de dezembro de 1997;

Constituição Federal: Art. 150. Sem prejuízo de outras garantias asseguradas ao contribuinte, é vedado à União, aos Estados, ao Distrito Federal e aos Municípios: VI – instituir impostos sobre: c) patrimônio, renda ou serviços dos partidos políticos, inclusive suas fundações, das entidades sindicais dos trabalhadores, das instituições de educação e de assistência social, sem fins lucrativos, atendidos os requisitos da lei;

CEBRASPE (2023);

QUESTÃO ERRADA: A não cumulatividade das contribuições ao PIS e à COFINS opera de maneira diversa da não cumulatividade do imposto sobre produtos industrializados ([PI) e do ICMS, visto que é incompatível com a técnica da base sobre base, competindo ao legislador constitucional disciplinar o funcionamento da sistemática.

A não cumulatividade das contribuições ao PIS e à COFINS opera de maneira diversa da não cumulatividade do imposto sobre produtos industrializados ([PI) e do ICMS, visto que é incompatível com a técnica da base sobre base, competindo ao legislador constitucional disciplinar o funcionamento da sistemática.

O regime de não cumulatividade do PIS/COFINS é semelhante ao regime de não cumulatividade do IPI e do ICMS?

Resposta: NÃO!

Por quê?

NO PIS/COFINS: FACULTATIVO

a não cumulatividade da COFINS e do PIS/PASEP não é obrigatória e depende de previsão em lei, que irá definir as regras aplicáveis (artigo 195, § 12 da CF/88).

Alguns créditos são obtidos pela aplicação da alíquota da não cumulatividade sobre a despesa = método base contra base. Isso quer dizer que se aceita a dedução de créditos financeiros (como decorrentes de aluguéis pagos a PJ e as depreciações do ativo mobilizado) (JUSTIFICATIVA PARA ITEM III ESTAR ERRADO

NO IPI/ICMS: OBRIGATORIO; Não cumulatividade do ICMS e do IPI é obrigatória e baseada no texto constitucional.

Os créditos são em regra: físicos, reais e condicionais = método imposto contra imposto.

Isso quer dizer que NÃO se aceita a dedução de créditos financeiros (como decorrentes de aluguéis pagos a PJ e as depreciações do ativo mobilizado). 

CEBRASPE (2023);

QUESTÃO CERTA: O conceito de insumo, para fins de aplicação da não cumulatividade das contribuições ao PIS e à COFINS, deve abranger a essencialidade ou a relevância do item, que pode ser bem ou serviço, para o desenvolvimento da atividade económica desempenhada pelo contribuinte.

Trata-se do entendimento firmado pelo STJ no julgamento do Recurso Especial 1.221.170/PR, na sistemática dos recursos repetitivos (Tema 779 – STJ), cuja tese fixada foi a seguinte:

  • (a) é ilegal a disciplina de creditamento prevista nas Instruções Normativas da SRF ns. 247/2002 e 404/2004, porquanto compromete a eficácia do sistema de não-cumulatividade da contribuição ao PIS e da COFINS, tal como definido nas Leis 10.637/2002 e 10.833/2003; e (b) o conceito de insumo deve ser aferido à luz dos critérios de essencialidade ou relevância, ou seja, considerando-se a imprescindibilidade ou a importância de determinado item – bem ou serviço – para o desenvolvimento da atividade econômica desempenhada pelo Contribuinte.
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CEBRASPE (2023);

QUESTÃO ERRADA: A vedação legal de creditamento concernente às despesas com aluguel e aos custos decorrentes de arrendamento mercantil, inclusive de bens que já integravam o patrimônio da pessoa jurídica quando do advento dessa norma legal proibitiva, considerado o regime não cumulativo das contribuições ao PIS e à COFINS, é incompatível com a CF, pois desrespeita o princípio da isonomia e da proteção à confiança.
Assinale a opção correta.

 tal vedação é compatível com a CF. Conforme recente julgado do STJ (REsp 1747824-SP), durante a vigência do arrendamento mercantil, é possível deduzir da base de cálculo da contribuição ao PIS e da COFINS as receitas oriundas da alienação de bens do ativo permanente.

CEBRASPE (2023):

QUESTÃO CERTA: A contribuição devida pelo empregador em caso de desligamento de empregado sem justa causa, conforme previsão da Lei Complementar (LC) n.º 110/2001, possui natureza jurídica de: contribuição social geral, tendo por finalidade não exclusiva, embora já exaurida, a recomposição do FGTS, considerada a decisão do STF que determinou a reposição do poder aquisitivo dos saldos das contas do FGTS.

– STF no RE 878313, trata-se de contribuição social geral que tem por finalidade não exclusiva a recomposição do FGTS:

“(…) 1. O tributo previsto no art. 1° da Lei Complementar 110/2001 é uma contribuição social geral, conforme já devidamente pacificado no julgamento das ADIs 2556 e 2558. (…) 3. O objetivo da contribuição estampada na Lei Complementar 110/2001 não é exclusivamente a recomposição financeira das perdas das contas do Fundo de Garantia do Tempo de Serviço – FGTS em face dos expurgos inflacionários decorrentes dos planos econômicos Verão e Collor.” (RE 878313, Relator(a): MARCO AURELIO, Relator(a) / Acórdão: ALEXANDRE DE MORAES, Tribunal Pleno, julgado em 18/08/2020, PROCESSO ELETRÔNICO REPERCUSSÃO GERAL – MÉRITO DJe-221 DIVULG 03-09-2020 PUBLIC 04-09-2020).

CEBRASPE (2023);

QUESTÃO CERTA: O conceito de insumo, para fins de aplicação da não cumulatividade das contribuições ao PIS e à COFINS, deve abranger a essencialidade ou a relevância do item, que pode ser bem ou serviço, para o desenvolvimento da atividade económica desempenhada pelo contribuinte.

Trata-se do entendimento firmado pelo STJ no julgamento do Recurso Especial 1.221.170/PR, na sistemática dos recursos repetitivos (Tema 779 – STJ), cuja tese fixada foi a seguinte:

  • (a) é ilegal a disciplina de creditamento prevista nas Instruções Normativas da SRF ns. 247/2002 e 404/2004, porquanto compromete a eficácia do sistema de não-cumulatividade da contribuição ao PIS e da COFINS, tal como definido nas Leis 10.637/2002 e 10.833/2003; e (b) o conceito de insumo deve ser aferido à luz dos critérios de essencialidade ou relevância, ou seja, considerando-se a imprescindibilidade ou a importância de determinado item – bem ou serviço – para o desenvolvimento da atividade econômica desempenhada pelo Contribuinte.

CEBRASPE (2023);

QUESTÃO ERRADA: A vedação legal de creditamento concernente às despesas com aluguel e aos custos decorrentes de arrendamento mercantil, inclusive de bens que já integravam o patrimônio da pessoa jurídica quando do advento dessa norma legal proibitiva, considerado o regime não cumulativo das contribuições ao PIS e à COFINS, é incompatível com a CF, pois desrespeita o princípio da isonomia e da proteção à confiança.
Assinale a opção correta.

 tal vedação é compatível com a CF. Conforme recente julgado do STJ (REsp 1747824-SP), durante a vigência do arrendamento mercantil, é possível deduzir da base de cálculo da contribuição ao PIS e da COFINS as receitas oriundas da alienação de bens do ativo permanente.

CEBRASPE (2023):

QUESTÃO CERTA: A contribuição devida pelo empregador em caso de desligamento de empregado sem justa causa, conforme previsão da Lei Complementar (LC) n.º 110/2001, possui natureza jurídica de: contribuição social geral, tendo por finalidade não exclusiva, embora já exaurida, a recomposição do FGTS, considerada a decisão do STF que determinou a reposição do poder aquisitivo dos saldos das contas do FGTS.

– STF no RE 878313, trata-se de contribuição social geral que tem por finalidade não exclusiva a recomposição do FGTS:

“(…) 1. O tributo previsto no art. 1° da Lei Complementar 110/2001 é uma contribuição social geral, conforme já devidamente pacificado no julgamento das ADIs 2556 e 2558. (…) 3. O objetivo da contribuição estampada na Lei Complementar 110/2001 não é exclusivamente a recomposição financeira das perdas das contas do Fundo de Garantia do Tempo de Serviço – FGTS em face dos expurgos inflacionários decorrentes dos planos econômicos Verão e Collor.” (RE 878313, Relator(a): MARCO AURELIO, Relator(a) / Acórdão: ALEXANDRE DE MORAES, Tribunal Pleno, julgado em 18/08/2020, PROCESSO ELETRÔNICO REPERCUSSÃO GERAL – MÉRITO DJe-221 DIVULG 03-09-2020 PUBLIC 04-09-2020)

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  468. Thanks for the helpful article. It is also my opinion that mesothelioma has an very long latency period of time, which means that indication of the disease won’t emerge until 30 to 50 years after the initial exposure to mesothelioma. Pleural mesothelioma, that is the most common style and impacts the area across the lungs, may cause shortness of breath, chest pains, as well as a persistent cough, which may lead to coughing up our blood.

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  482. Thanks for discussing your ideas on this blog. Additionally, a fairy tale regarding the banking companies intentions whenever talking about foreclosures is that the standard bank will not take my repayments. There is a certain amount of time in which the bank will need payments occasionally. If you are also deep inside hole, they may commonly desire that you pay the actual payment completely. However, that doesn’t mean that they will have any sort of repayments at all. In the event you and the traditional bank can have the ability to work one thing out, the foreclosure approach may halt. However, in case you continue to skip payments within the new program, the home foreclosure process can just pick up where it was left off.

  484. Thanks for your ideas. One thing I’ve got noticed is that banks along with financial institutions really know the spending behavior of consumers and also understand that most people max away their cards around the breaks. They wisely take advantage of this real fact and start flooding your inbox and also snail-mail box by using hundreds of Zero APR credit card offers immediately after the holiday season finishes. Knowing that in case you are like 98 of the American general public, you’ll leap at the chance to consolidate card debt and switch balances for 0 apr interest rates credit cards.

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  499. I do believe that a foreclosures can have a significant effect on the client’s life. House foreclosures can have a 8 to decade negative affect on a debtor’s credit report. A borrower who have applied for home financing or virtually any loans for example, knows that a worse credit rating is usually, the more tricky it is for any decent loan. In addition, it may possibly affect a new borrower’s capability to find a quality place to let or rent, if that turns into the alternative real estate solution. Interesting blog post.

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  512. I have observed that over the course of making a relationship with real estate managers, you’ll be able to come to understand that, in every real estate contract, a percentage is paid. All things considered, FSBO sellers really don’t “save” the commission payment. Rather, they fight to win the commission by way of doing the agent’s job. In the process, they devote their money and also time to execute, as best they’re able to, the duties of an real estate agent. Those obligations include displaying the home through marketing, introducing the home to buyers, making a sense of buyer desperation in order to induce an offer, arranging home inspections, managing qualification checks with the mortgage lender, supervising maintenance tasks, and aiding the closing.

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  547. Thanks for your write-up. One other thing is always that individual states in the United states of america have their very own laws of which affect house owners, which makes it extremely tough for the our lawmakers to come up with the latest set of recommendations concerning foreclosures on householders. The problem is that a state provides own regulations which may have impact in an adverse manner with regards to foreclosure policies.

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  552. With havin so much written content do you ever run into any issues of plagorism or copyright violation? My blog has a lot of exclusive content I’ve either authored myself or outsourced but it looks like a lot of it is popping it up all over the internet without my permission. Do you know any methods to help reduce content from being stolen? I’d certainly appreciate it.

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  555. I should say also believe that mesothelioma cancer is a exceptional form of cancer that is commonly found in these previously familiar with asbestos. Cancerous tissues form while in the mesothelium, which is a defensive lining that covers the majority of the body’s bodily organs. These cells ordinarily form inside lining with the lungs, abdominal area, or the sac which encircles one’s heart. Thanks for revealing your ideas.

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