SPED 2019

UPDATE: SAP Released the ECC OSS Note: 2710860 – EFD ICMS IPI – Layout 13

CONFAZ (National Council of Finance Policy), published in the Federal Official Gazette, the ACT COTEPE/ICMS 44 (link). This official notice contains a link to the new layout for SPED EFD ICMS/IPI (SPED FISCAL) that is required to the January 2019 period (that is, it is due when you report the file in February).

Here is a link to this document (note that his is version 001 and it may change while the due date approaches): Nota Técnica EFD ICMS IPI nº 2018.001

Link

What is changing?

The first big change is that the ACT COTEPE/ICMS 09/2008 was revoked. This ACT was dealing with technical specifications to the EFD file generation. The requirements in this act were then added to the Layout 13 Contributor’s Guide – Technical Note EFD ICMS IPI 2018.001. One of the goals with this technical specification is that, to each SPED version, there will one technical note, making the information requested clearer.

The next big change in this technical note was the introduction to the new “Guia Pratico da EFD ICMS/IPI” (EFD ICMS/IPI Contributor Guide), which will jump from version 2.0.22 to version 3.00. We all know that when versions change in the first digit to the left, that means “big changes”. This Contributor Guide has a list of 12 major layout changes, which you will see in this post. Those changes are required to the SPED File that you will report to January 2019 period. The changes are listed on page 13 in the sub-section 8 and Page 271:

  1. Bock B added – ISS Calculation (Sefaz DF)
  2. Register D100 – Field 11 – Changes in the field Validation
  3. Register C176 – Field 19 – Changes in the Field / Added Field 27
  4. Register C170 – Added Field 38
  5. Added Register C191
  6. Register C190 – Change fields description and fulfilling orientation: 05, 07 and 09
  7. Changes in Register C177;
  8. Changes in Register 1600;
  9. Block K: changes in the decimal notation (from 3 to 6) for quantity fields
  10. Register C100: change exception 2 text and added exception 10
  11. Added Registers 1960, 1970, 1975 and 1980
  12. Register K290: updated the description about the concept of grouped manufacturing

Let’s review those changes in more details:

  1. Bock B added – ISS Calculation (Sefaz DF)

That’s the most important change to the SPED in 2019, and it is also the one that has concerned most the tax contributor, specially the small services providers. This block deals with the ISS Tax Calculation reporting (Service Tax), leaving the idea that, from January 2019, it will be mandatory to all tax contributors to inform the transactions with ISS due, that is, services providers that today are not due to ICMS and IPI, but only to ISS, would need to start reporting the SPED EFD.

However, looking the Block B in more details, the Block B is (at this moment) only required from the tax payers in the DF region (noted in page 243), while tax contributors in other regions should only present the opening and closing registers of this block. There some relief in this information, but we know that when such significant changes are to be introduced, they start with one region before rolling it out to all the regions. In addition to that, one of the SPED goals is to promote the integration between Federal, States and Municipalities, integrating all the Taxes collection report, and for that, it would require that all regions report the ISS on block B.

The message here is, if you are not in the DF region, you shouldn’t be concerned, for now, but should be prepared to report the block B soon.

  1. Register D100 – Field 11 – Changes in the field Validation

Record D100 is where the various CTe/CTRC (freight nota fiscals) are reported. The field 11 (Posting date in the fiscal document) is where the freight nota fiscal issuing date is informed. Starting in January 1st, 2019, the new validation rule in this field will not allow that paper freight nota fiscals (CTRC) are reported with issuing date greater or equal to January 1st, 2018.

That’s necessary because the SINIEF Adjustment 09/2007 inc VIII of 24th clause defined the maximum deadline to issue paper freight invoices as being October 2nd, 2017, so that this rule can be enforced, the changed in D100 field 11 were necessary. The following Freight Nota Fiscals are affected by this validation:

  • Nota Fiscal de Serviço de Transporte – Transportation Service Nota Fiscal – Model 7
  • Conhecimento de Transporte Rodoviário de Cargas – Road Load Transport acknowledgment – Model 8
  • Conhecimento de Transporte de Cargas Avulso – Independed Load Transport acknowledgment – Model 8B
  • Conhecimento de Transporte Aquaviário de Cargas – Waterway Load Transport acknowledgment – Model 9
  • Conhecimento Aéreo – Air Acknowledgment – Model 10
  • Conhecimento de Transporte Ferroviário de Cargas – Rail Load Transport acknowledgment – Model 11
  • Conhecimento de Transporte Multimodal de Cargas (CTMC) – Multi-modal Load Transport acknowledgment – Model 26
  • Nota Fiscal de Serviço de Transporte Ferroviário de Cargas – Rail Load Transportation Service Nota Fiscal – Model27

All the Nota Fiscal types listed above were replaced by the Electronic Freight Nota Fiscal (CT-e) model 57, Electronic Ticket (BP-e) model 63 and Other Services Electronic Freight Nota Fiscal (CT-e OS) model 67.

  1. Register C176 – Field 19 – Changes in the Field / Added Field 27

Register C176 is used to inform the ICMS restitution occurred in transactions with ICMS Tax Substitution, related to the products return/devolution or rejected by the destination. The field 19 (Restitution Reason Code) indicates the reason why the item was returned or rejected. This field used to have 6 different reason codes, but in 2019 there will be 7. The new code is “Venda Interna para Simples Nacional” (internal sale to national simples).

It was also added the field 27 (Unit amount of restitution [complete or partial] of FCP occurred from ST split) to this register. This field states the partial or total referent to the FCP (Poverty Fight Fund) when there were split in the ICMS ST. This field should only be used in accordance to the rules of each Region/UF where the tax contributor is located when the products are subjected to the FCP.

  1. Register C170 – Added Field 38

The Record C170 is where the information of each nota fiscal item is reported. The field 38 (Rebate amount non-taxable and non-commercial) used to be only in the C10 register (Nota Fiscal totals), but from January 2019, it will be possible to detail this information at product’s level, which will bring more transparency regard to the taxation applied to the item that has the fiscal benefit.

The non-taxable rebate is only applicable to some states, so that, to the Nota Fiscal issuer to have the benefit, it is necessary to show that in the fiscal document where the rebate was given to the customer.

  1. Added Register C191

The register C191 (FCP – Poverty Fight Fund information in the NF-e) was added to follow the update in the NF-e 4.00 XML layout, in which now has the field to report the amounts related to the FCP, either in own transactions, as well as in transactions that includes Tax Substitution (FCP ST).

It is important to note that this record has no relation with the transaction with DIFAL due to non-tax contributor, in which the tax reporting is still done in the C101 register (Complement information from fiscal documents when transaction is inter-state to end-consumer non-tax contributor EC87/15)

  1. Register C190 – Change in fields description and orientation on fulfilling: 05, 07 and 09

The changes in register C190 are directly related to the addition of register C191 listed above. All the fields (05 – Transaction amount, 07 – ICMS Base amount, and 09 – ICMS ST Amount) had their fulfilling rules changed to accommodate the FCP amounts.

  1. Changes in Register C177;

Register C177 (Transaction with products subject to IPI control Seal) will no longer inform the type and quantity of IPI control seals used in the goods issuance by the manufacturers or importers of products that were subject to this obligation, such as: hot beverage, cigarettes and watches. Starting in January 2019, this field will be called “Items Complement – Others information” and it will be reported only for the tax contributors that are required for the specific legal rule in its UF/Region. This new record will group information added to the item in accordance to the Table 5.6 (Fiscal Document Item Additional Information Table) available in the Contributor Guide.

  1. Changes in Register 1600;

The change in Register 1600 added to this register, information referring to the total amounts in sales made via store (private label) and other electronic channels. Up to the end of 2018, the requirement was only for sales made via Credit Card or Debit Card from the card administrators, informing the total sales amount, excluding reversals, cancellation and others receipts not tied to the main operational activity of the tax contributor.

  1. Block K: changes in the decimal notation (from 3 to 6) for quantity fields

To all fields in block K where quantity is reported, the number of decimal places were extended from 3 to 6 to improve the precision in the information reported.

  1. Register C100: change exception 2 text and added exception 10

The exception 2 in register C100 defines the general rule to not reporting the register C170 when the NF is issued by the tax contributor (own issued) and set the rules to this general exception, such as when there are Nota Fiscals that are presented in register C176 (restitution of ICMS ST). The change in the exception 2 targets the change in the register C177 that deals with complement information of items with exception in the general exception 2.

The exception 10 is like a confirmation to the exception 2, emphasizing the requirement of reporting the register C170 to the situations where the C177 needs to be reported, when the NF is not issued by the tax contributor.

  1. Added Registers 1960, 1970, 1975 and 1980

The 4 registers goal is to prepare the SPED EFD ICMS/IPI to accommodate tax reporting send from State PE – Pernambuco, as the registers are related to the SEF II program (Fiscal Bookkeeping System) from SEFAZ/PE and covers a specific need from the tax contributors that are under the PRODEPE (Pernambuco State Development Program). In this bookkeeping, it is necessary to inform the GIAF (Information Guide of Tax and Financial Incentive collection) to the following industry segments:

– Industry (presumed credit)

– Importation (Deferral on entry and presumed credit on subsequent issue)

– Importation (Internal issues by Rate range)

– Distribution Central (Incomings and Outgoings)

The rules and details of reporting the GIAF are very wide and it’s relation with PRODEPE and the SEF II are complex, it is like if the SEFAZ/PE had its own SPED EFD.

  1. Register K290: updated the description about the concept of grouped manufacturing

Up to the end of 2018, grouped manufacturing was the manufacturing of more than one product resulting from the consumption of one or more inputs in the same process. But starting in 2019, this concept gets more details, which emphasizes as being grouped manufacturing, the fact that it is not possible to record the inputs’ consumption in the same manufacturing flow. One other relevant aspect in the concept extension is related to the resulting products classification type, which can depend on the relevance of the sales of those products to tax contributors or be sorted as co-products or sub-products.

This change allows the tax contributor more transparency in how to sort their manufacturing process, resulting in less mistakes in the EFD.

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What’s next?

The changes are significant, and if you have worked in a SPED Layout upgrade, you may know that the due date may change, but it may not, so you have to be prepared to January and avoid reporting the file with inconsistencies and end paying fines for that.

You may also know that those changes take times to develop/implement, test and etc., so plan in advance to start working on these changes.

If your company runs SPED on SAP, there is no OSS Note released to cover those changes yet, but you can check regularly the SAP Legal Change Notes app via ONE Support Launchpad.

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