In at least two recent opportunities, the IRS has admitted qualifying certain expenditures under the concept of inputs for purposes of appropriating COFINS credits and contributing to PIS in the non-cumulative system.
These arise out of two responses from the General Coordination Office for the Taxation System (COSIT) to doubts raised by taxpayers in consultation processes. Both cases reveal a change of mood in the face of the well-known resistance of the Federal Revenue to recognize the expansion of the list of credits, even after the STJ has defined essentiality and relevance as guidelines for assessing the nature of the credit subject to appropriation.
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