The Brazilian Revenue Service, through Enquire Solution n. 239/2012, published on January 08/2013, clarified that there is no need to share revenues to use the PIS and COFINS credits over expenses with electric power and rents, in case the company is subject to the taxation according to the non-cumulative regime, even if it obtains revenues taxed at a zero rate or consequent of the sale of product submitted to the regime of tax substitution as substituted.

(Enquire Solution n. 239, Dec. 06.2012, DOU-I, Jan. 08.2013).