IRS Superintendence of the 8th Tax Region (SRRF8) issued Answer to Consultation n. 76, of March 27, 2013, which provided clarifications on the taxation of amounts assessed under the Regime for Reimbursement of Tax Amounts to Exporting Companies (Reintegra).
SRRF8 understood that such amounts are revenues of the beneficiary since they correspond to a current subvention. Thus, they must be included in PIS and COFINS taxable basis when these taxes are assessed under the non-cumulative regime. Moreover, authorities understood that these amounts must also be considered to assess the beneficiary’s operational profit, being included in IRPJ and CSLL bases.
(Answer to Consultation n. 76, 03.27.2013).