STF vai discutir necessidade de edição de lei complementar para cobrança do DIFAL do ICMS

Conforme noticiado pelo STF ontem (29/06), o Tribunal decidiu declarar a repercussão geral de importante controvérsia em matéria tributária, decidindo levar a julgamento, pelo Plenário, da necessidade ou não de edição de lei complementar para cobrança do diferencial de alíquota (DIFAL) do ICMS nas operações interestaduais.

O DIFAL foi introduzido em 2015, por meio de Emenda Constitucional, e prevê, dentre outro temas, a adoção da alíquota interestadual nas operações e prestações que destinem bens e serviços a consumidor final, contribuinte ou não do ICMS, localizado em outro Estado. A regra prevê que caberá ao Estado do destinatário o imposto correspondente à diferença entre a alíquota interna e a interestadual do ICMS, o que impacta, certamente, no custo dos produtos e serviços sujeitos ao imposto.

A questão não envolve discutir a constitucionalidade do DIFAL, mas sim o meio legislativo para que possa ser operacionalizado pelos Estados. Hoje, o tema é discutido por normas estaduais, e não com uma lei “nacional”, que seria a lei complementar, que deve ser aprovada pelo Congresso Nacional.

Referência: Tema 1093, ARE 1237351/DF

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