IMPORTANT NOTICE
BLOCK K ADJUSTMENT SINIEF No. 25, OCTOBER 1, 2021
Changes SINIEF Adjustment No. 02/09, which provides for Digital Tax Bookkeeping – EFD.
On October 8, 2021, it was published in the DOU Adjustment Sinief nº 25, of October 1, 2021, which maintains the current version of Block K as of January 2022.
As is known, the Production and Inventory Control Register, a tax book established in 1970, must be recorded by ICMS and IPI taxpayers to record data relating to their tax documents and production orders, listing the inputs and outputs of products and goods, production and quantities of stocks of goods, raw materials, inputs, packaging, final product and calculated losses.
Block K of SPED Fiscal is the digital version of the Production and Inventory Control Record book (model 3), whose data must be electronically recorded and sent to the national environment of the Public Digital Bookkeeping System (SPED) that started from of 2017. The purpose of this tax obligation is to provide the tax authorities with data on tax documents and other documents for internal use that relate to the movement of production and stock of goods and inputs, aiming at the inspection of taxes (ICMS and IPI) calculated from of this information. The big issue is to reach a common denominator that meets the tax authorities’ requirements without impacting the companies’ internal processes and without violating the industrial secrecy environment.
After many discussions with COTEPE and CONFAZ, Sinief Adjustment nº 25/2021 was published, determining that the complete and very complex version of Block K will not come into force in January 2022, as previously foreseen. The maintenance of the current version has no term and will only be replaced when a simplified version of Block K is developed by CONFAZ. 16 of Law No. 13.874, of September 20, 2019 (Declaration of Economic Freedom Rights and establishes free trade guarantees).
In this scenario, the schedule looks like:
January 1, 2017, restricted to information on stock balances recorded in Registers K200 and K280, for industrial establishments classified in divisions 10 to 32 of the National Classification of Economic Activities (CNAE);
of January 1, 2019, corresponding to the complete bookkeeping of Block K, for industrial establishments classified in divisions 11, 12 and in groups 291, 292 and 293 of CNAE;
of January 1, 2020, corresponding to the complete bookkeeping of Block K, for industrial establishments classified in divisions 27 and 30 of CNAE;
the implementation of the simplified system for the bookkeeping of Block K, referred to in the sole paragraph of article 16 of Law No. 13.874, of September 20, 2019, for industrial establishments classified in division 23 and in groups 294 and 295 of the CNAE ;
the implementation of the simplified system for the bookkeeping of Block K, referred to in the sole paragraph of article 16 of Law No. 13.874/19, for industrial establishments classified in divisions 10, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 24, 25, 26, 28, 31 and 32 of the CNAE.
SilveiraLaw’s tax team is at your disposal for any necessary clarifications.