Ruy Fernando Cortes de Campos and Gabriel Castro, from the Tax Law team at Manucci Advogados, published an article on Revista Consultor Jurídico (ConJur) about the PIS/COFINS credit on opening stock during the transition from Presumed Profit to Actual Profit. They highlight the possibility of utilizing the presumed credit calculated on the opening stock, as provided for in laws No. 10.833/2003 and 10.637/2002.
The article explores two distinct scenarios: the acquisition of stocks in the domestic market and the importation of goods. In the first case, the authors explain the applicable rate of 3.65%, as decided by the STF. In the second, they discuss the restriction imposed by the Federal Revenue on the PIS/COFINS credit for imported stocks, offering arguments for judicial contestation.
This reading is essential for those seeking to understand the legal and practical implications of this transition.
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