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VEDAÇÃO DA COMPENSAÇÃO COM DÉBITOS DE IRPJ E CSLL APURADOS POR ESTIMATIVAS MENSAIS

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A compensação entre débitos e créditos tributários federais ainda é objeto de muitos questionamentos por parte dos contribuintes, sobretudo quando falamos das vedações impostas pela legislação.

Uma delas refere-se à impossibilidade de se efetuar o abatimento de créditos apurados pela empresa com débitos relativos ao recolhimento mensal por estimativa do Imposto de Renda da Pessoa Jurídica (IRPJ) e da Contribuição Social Sobre o Lucro Líquido (CSLL).

Se você já se deparou com esta situação e ficou com dúvidas sobre o tema, leia o nosso artigo e entenda um pouco mais sobre o impedimento trazido pela Lei nº 13.670/2018.

Vedação prevista na Lei nº 13.670/2018 e a jurisprudência atual

Já não é novidade o fato de que a Lei nº 13.670/2018, no intuito de impedir a perda de arrecadação e inibir a realização de compensações supostamente indevidas, inseriu o inciso IX no parágrafo terceiro do artigo 74 da Lei nº 9.430/1996, proibindo a compensação de débitos oriundos do recolhimento mensal por estimativa do IRPJ e da CSLL.

Na época, o assuntou foi objeto de muita polêmica e a alteração promovida na legislação federal ensejou centenas de ações judiciais que visam afastar tal limitação.

Os tribunais, por sua vez, costumam confirmar a legalidade da norma, mantendo a vedação da compensação por entenderem que a regra estabelecida em 2018 não viola os princípios da confiança, da segurança jurídica e da boa-fé do contribuinte e que a lei em comento não prejudica os créditos das empresas, já que estes podem ser objeto de restituição ou ressarcimento ou, ainda, compensados com débitos relativos a outros tributos administrados pela Receita Federal do Brasil.

A jurisprudência majoritária demonstra também que o regime jurídico aplicável, isto é, a legislação que regula a compensação é aquela vigente na data em que se realiza o encontro de contas entre débitos e créditos, sendo insignificante, por exemplo, o fato do crédito ter sido eventualmente constituído anteriormente à vigência da Lei nº 13.670/2018[1].

O impedimento se aplica às compensações de débitos relativos às antecipações mensais de IRPJ e CSLL apuradas através de balancetes de redução ou suspensão?

Mas será que a vedação prevista na referida norma alcança também as antecipações mensais apuradas através de levantamento de balancetes de suspensão ou redução?

Sobre esse ponto, é importante esclarecer que as empresas tributadas pelo Lucro Real contam com duas alternativas de apuração e recolhimento do IRPJ e da CSLL devidos por estimativa.

A primeira delas encontra-se prevista no artigo 2º da Lei nº 9.430/1996, o qual estabelece que o cálculo do valor da estimativa mensal é feito mediante a aplicação de um percentual de presunção sobre a receita bruta auferida mensalmente pela pessoa jurídica.

Por sua vez, a segunda opção, prevista no artigo 35 da Lei nº 8.981/1995, autoriza o contribuinte a suspender ou reduzir o pagamento mensal do IRPJ e da CSLL devidos sobre a base de cálculo estimada, desde que comprove, através de balanços ou balancetes mensais, que o valor acumulado já recolhido pela empresa excede o montante dos impostos devidos, calculados com base no lucro real do período em curso.

Superada esta questão, percebe-se, ao analisar o inciso IX do parágrafo terceiro do artigo 74 da Lei nº 9.430/1996, que a regra restritiva abarca “os débitos relativos ao recolhimento mensal por estimativa do Imposto sobre a Renda das Pessoas Jurídicas (IRPJ) e da Contribuição Social sobre o Lucro Líquido (CSLL) apurados na forma do art. 2º desta Lei.”

Diante disso, numa primeira análise, nos parece razoável e existem argumentos para defender o entendimento de que apenas os débitos apurados por estimativa com base em percentual aplicado sobre a receita bruta mensal não podem ser compensados.

Apesar disso, a Receita Federal do Brasil já se posicionou, através da Solução de Consulta nº 279/2019 – Cosit, no sentido de que os balanços/balancetes mensais de redução ou suspensão constitui técnica para melhor adequação do valor a ser pago, mas não tem o condão de alterar a sua natureza, já que o valor reduzido continua a ser estimativa mensal, sujeitando-se à vedação estabelecida no artigo 74, §3º, inciso IX, da Lei nº 9.430/1996.

O que os tribunais dizem sobre o tema?

E não é só! Ao apreciar o tema, o Tribunal Regional Federal da Terceira Região, por exemplo, e o Superior Tribunal de Justiça também têm assumido posicionamentos contrários aos contribuintes.

Na maioria das decisões judiciais envolvendo o tema, os Tribunais demonstram que a alternativa constante no artigo 35 da Lei nº 8.981/1995 não é autônoma e trata-se de uma faculdade conferida ao contribuinte que optou pela apuração anual dos tributos federais pelo regime de estimativa, de modo que a sistemática dos balancetes faz parte do pagamento através da base de cálculo estimada[2].

Considerações finais

É importante que os contribuintes estejam atentos às vedações previstas na legislação federal vigente e à jurisprudência atual, a fim de que não sejam surpreendidos com a não homologação das compensações efetuadas, o que, certamente, dará ensejo a cobrança do débito objeto do procedimento compensatório, acrescido dos encargos moratórios legais, inclusive, da multa isolada de 50% sobre o valor devido[3].

Equipe Tributária do Molina Advogados

[1] STJ – AgInt no Recurso Especial nº 1929158 – PR, Relator Ministro Benedito Gonçalves, julgado em 19/10/2021.

STJ – Agravo em Recurso Especial nº 1932454 – SP, Relator Ministro Herman Benjamin, julgado em 26/10/2021.

[2] STJ – Recurso Especial nº 1967176 – PR, Relator Ministro Mauro Campbell Marques, julgado em 26/11/2021.

[3] Artigo 74, parágrafo 17º da Lei nº 9.430/1996.

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