PIS/COFINS
Zero rate is decided item by item
Classification belongs neither to the sector nor to the company. It belongs to each product.
Article 3 of Law 12,973/2014 set total revenue of R$ 78 million in the previous year as the threshold above which full taxable income stops being a choice and becomes an obligation. It is a figure that separates two worlds. On this side, assessment is presumed and the tax registry matters little. On the other, PIS and COFINS become non-cumulative, input credit enters the picture, and every line of the product registry becomes a tax decision — multiplied by thousands of items and by every month of the year.
The point almost nobody treats with due care is that classification belongs neither to the sector, nor to the company, nor to the traditions of the house: it belongs to each product, by its tariff code, its description and the nature of the operation. Two competitors in the same trade, selling equivalent goods, can carry different burdens for a whole decade simply because, in some year, somebody chose a code and the system went on copying it. The error is rarely gross — it is a matter of nuance. And nuance, repeated for sixty months, is the size of an annual investment budget.
The credit test has also shifted its axis. What authorises an input credit is not the accounting label but the essentiality and relevance of the item to the activity — a test of reality, not of nomenclature. That moves the discussion from the spreadsheet to the factory floor: what actually enters the process, what is indispensable, what would become unviable without that item. It is work that requires someone able to read both the rule and the operation — and the rarity of that combination explains much of what gets left behind.
The test, to run this week: ask what percentage of last month's purchases generated credit, and the criterion used to decide. Two pieces of information, one sentence each. If the answer comes back as a round number and an "it is what we have always done", you have found the nuance — it tends to live exactly there. And there is an honest bonus in this work: the same review that recovers the past is the registry the company will need to start correctly under the new system. Done once, it serves twice.
Diagnosis with defined scope, timeline and price; every thesis classified by risk, in writing, before any decision of yours. Execution follows the administrative route, with a calculation trail — and remuneration falls on realised benefit.
Official sources, at the exact point — the article of law, the service or the search you can use today. None replaces analysis of the specific case, which is our work.
No thesis moves forward without its classification written beside it. That is what separates a survey from a promise.
Say in two lines what you need to resolve. An account manager replies personally, in business hours, and the conversation starts where it makes a difference.
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