STF: julgamento da aplicação do ISS na base de cálculo do PIS/COFINS

O STF deu início ao julgamento do Tema 118 de Repercussão Geral, que tem como objetivo discutir a constitucionalidade da inclusão do valor do ISS na base de cálculo do PIS/COFINS.

No último dia 14/08, o Relator do processo, Ministro Celso de Mello, liberou seu voto pela inconstitucionalidade da inclusão do ISS na base de cálculo do PIS/COFINS, na esteira do que o próprio STF decidiu anteriormente acerca da inclusão do ICMS na base de cálculo das contribuições referidas (Tema 69).

Ontem (19/08), o Ministro Dias Toffoli pediu vista do processo e o julgamento foi suspenso.

De todo modo, a tendência é que o julgamento seja favorável aos contribuintes, no sentido de que a inclusão do ISS seja também considerada inconstitucional. No caso do ICMS, o julgamento só não foi concluído na parte que trata do pedido de devolução do valor pago a maior pelos contribuintes (repetição de indébito) dos últimos 5 anos, por conta da pressão nas contas públicas federais, e tal situação certamente será objeto de discussão neste tema do ISS.

Em resumo, o STF vem consolidando seu entendimento no sentido de que o valor pago a título de ICMS e ISS não pode integrar a base de cálculo do PIS e da COFINS. Tal declaração ainda demanda a propositura de ação judicial pelos contribuintes. Em contraponto, já existe forte movimentação, no campo da Reforma Tributária, para substituição do PIS e da COFINS por outros tributos.

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