Remember, that the validation of all inbound supplier Nota Fiscals is mandatory. Many companies are still accomplishing this manually. One company had over 15 individuals manually entering supplier invoices into the government portal. Another company had over 20. Yet another company realized they had not audited and archived almost 1 million nota fiscals from their suppliers. At 500 Reais penalty per invoice, the fines can add up quickly. The real time audits are just starting and with the SEFAZ increasing their revenue stream by ~58 Billion US dollars in 2012 due to penalties and collection of back taxes, you really need to be prepared come December 2013. There are two important documents you have to collect, validate, and archive for 5 years: NFe Goods and CTe the transportation documents.
NF-e for Goods
- Taxes assigned at State level, so much higher adoption and standardization
- Digitally signed by emitter for non-repudiation and authentication to receiver
- Electronic file is the legal invoice – paper visualizations for human comfort only
- Invoices must be registered and approved before being sent
- Printed DANFE must accompany goods in transit for validation en route
- Inbound invoices must be validated and there are new “Eventos” processes taking place to eliminate ghost transactions.
- The inbound Eventos are required in the Oil & Gas industry and also in Rio Grande del Sul for invoices over 100K Reais. It is expected that other states will adopt the 100K Reais policy in the coming years.
- Archive for 5 years by sender
Under clause ten, first paragraph, of the adjustment SINIEF 07/05, as amended by setting SINIEF 04/06: "§ 1 “The recipient shall check the validity and authenticity of the NF-e and the existence of Authorization for any NF-e”
Effective Since 2010 – see NF-e FAQ (Portuguese)
CT-e:
Brazil Transportation Document – is issued and stored electronically in order to document the provision of transport services, whose legal validity is guaranteed by the issuer’s digital signature and authorization of use provided by the tax administration. Examples of use would be a Waybill (model 10) or an Invoice for Transportation Service (model 7 when transporting cargo). As of December 2013, all modes of transportation are mandated. This is not just an issue for the 3PL transportation company, the payer of the fees must also obtain and validate the CTe. There is also a concept of the MDFe which has use for contractors as well as for the aggregation of CTe on a single shipment (i.e. 10 NFe, 10 CTe each one referencing one NFe, and 1 MDFe referencing the 10 CTe)
SEFAZ CT-e Link to the FAQ (Portuguese)
Ensure you have a strategy in place to meet the legal compliance, as the penalties in Brazil are severe and expensive.
