aproveitamento de créditos do PIS e da COFINS sobre fretes no setor do agronegócio

Fabrício Fonseca da Rocha; Vanessa de Cillos Silva

DOI: 10.22167/2675-6528-202602888

Article derived from a Final Course Work (TCC), with content based on the student’s original work and adapted to the editorial format of the E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.

Abstract

The Brazilian agribusiness, a strategic sector of the economy, faces tax challenges related to the utilization of PIS and COFINS credits. The study described the potential for utilizing PIS and COFINS credits on contracted freight for the transfer of goods between establishments of the same taxpayer, within the specific context of the agricultural inputs sector, considering the impacts on tax management, tax planning, and fiscal risk mitigation. A qualitative, applied, and exploratory approach was adopted, through a case study in an agro-industrial company, and doctrinal and jurisprudential currents were analyzed, applying the “subtraction test” of the Superior Court of Justice. The results indicated that transfer freight in the agricultural inputs sector is an essential and relevant element for economic activity, not being configured as a mere administrative act, as its absence makes commercialization and revenue generation unfeasible. It was concluded that the classification of freight as an input is legitimate, requiring tax management to adopt technical criteria, robust documentation, and prudent measurement of fiscal risk to optimize efficiency and strengthen governance, especially in light of recent legislative changes and the transition to the Contribution on Goods and Services (CBS).

Keywords: Agribusiness; Tax credits; Transfer freight; PIS/COFINS; Subtraction test.

1. Introduction

The agribusiness holds a strategic position in the Brazilian economy, being responsible for a significant portion of the Gross Domestic Product and national tax revenue. Data from the Center for Advanced Studies in Applied Economics (CEPEA, 2022) indicate expressive growth in the sector in recent decades, consolidating it as a driver of wealth and attraction of investments. The appreciation of this segment is corroborated by Veja Negócios (2024), which points to its participation in 23.7% of the annual tax revenue, totaling R$790.51 billion out of a total of R$3.34 trillion.

In this scenario of economic relevance, the Program for Social Integration (PIS) and the Contribution for the Financing of Social Security (COFINS) represent significant components of the amount collected annually. As emphasized by Braghini (2018), these contributions are frequently the subject of discussions in administrative and judicial tax litigation, especially regarding the non-cumulative regime.

Taxpayers who opt for the “Lucro Real” (Real Profit) regime, operating in the agribusiness sector and subject to the non-cumulative PIS and COFINS system, face a challenging scenario in generating credits. This complexity is accentuated by the concept of “input” established by Special Appeal No. 1,221,170-PR. To serve diverse regions, the agrochemical and fertilizer industries, according to Law No. 14,785/2023 and Decree No. 4,954/2004, establish strategic distribution centers. Delivery speed is crucial, given the specificities of the agricultural field, such as pests and climatic conditions, as late delivery makes wealth generation unfeasible for all parties involved.

The transportation of these products from the manufacturing establishment to the distribution networks requires compliance with strict sanitary regulations, especially when the raw material is considered hazardous to human health. This requirement increases the complexity of the operation even before the sale is finalized. Although the freight transport service is regularly taxed by PIS and COFINS, allowing the acquirer to appropriate credits under the non-cumulative regime, Normative Opinion No. 05 of the Federal Revenue of Brazil (2018) imposed limits on the right to credit in operations of transporting goods between establishments of the same taxpayer.

The thesis established in Special Appeal No. 1,221,170-PR by the Superior Court of Justice (2010) defines input as an essential and relevant good for the commercialization of the final product. Cruz (2022) complements this view, understanding that credit is appropriable when it impacts the commercialization of products and services, reflecting in the increase in assets, which is the object of taxation of these contributions. However, while the STJ advocates for a case-by-case analysis of the concept of input, the Federal Revenue of Brazil (2024) adopts a more restrictive interpretation, considering such concepts too broad to be applied to the transfer of finished products, not authorizing the use of credits in these situations.

Given the recurrence of transfer operations in the agro-industrial sector and the controversies surrounding the appropriation of credits under the non-cumulative regime, it becomes essential to analyze the theoretical and jurisprudential currents that favor the use of credits when contracting freight for the transfer of finished products between establishments of the same taxpayer, focusing on the resources published by the Administrative Council of Tax Appeals (CARF). Through the analysis of these doctrinal and jurisprudential currents and the Subtraction Test Theory, developed in REsp No. 1,221,170-PR, we seek to support tax management decisions related to the secure appropriation of credits, the mitigation of tax risks, and tax planning in the agricultural inputs sector. The present work aims to describe the potential for utilizing PIS and COFINS credits arising from the contracting of freight between establishments of the same taxpayer in the agricultural inputs sector, considering the impacts on tax management, tax planning, and tax risk mitigation.

2. Material and Methods

The present study adopted a qualitative, applied, and exploratory approach, as outlined in the methodology. The central objective was to analyze the tax management practice related to the appropriation of PIS and COFINS credits in the agribusiness sector. The exploratory research sought to provide greater familiarity with the investigated problem, aiming to broaden the initial understanding and clarify little-discussed concepts, according to Gil (2024).

The choice for the qualitative approach was justified by the need to understand the meanings, perceptions, and interpretations inherent in the phenomenon studied. This approach emphasizes a deep understanding of contexts and experiences, valuing the interpretive analysis of the collected data, as proposed by Creswell and Creswell (2020). The goal was not statistical generalization, but rather depth in the analysis of the specific case.

As a research strategy, a case study was conducted in a large company in the agribusiness sector. The organization operates in the manufacturing and marketing of pesticides and fertilizers, being an optant for the “Lucro Real” (Real Profit) tax regime and included in the non-cumulative PIS and COFINS system. The company has its headquarters in São Paulo and branches strategically located in various regions of the country, especially in the north and northeast, to meet the demand of rural producers.

The empirical object of the analysis consisted of the operations of transfer of finished products and the respective freights contracted between the company’s own establishments. The focus of the investigation was the evaluation of the impacts of these operations on tax management, specifically regarding the appropriation of PIS and COFINS credits, the mitigation of fiscal risk, and the support for tax planning decisions.

Data collection was based on the analysis of secondary sources, including legal, administrative, and jurisprudential documents. The Normative Opinion No. 05 of the Brazilian Federal Revenue (2018), which imposes limits on the right to credit in transportation operations between establishments of the same taxpayer, and the Special Appeal No. 1,221,170-PR of the Superior Court of Justice (2010), which defines input, were examined.

Additionally, resources published by the Administrative Council of Tax Appeals (CARF, 2024) were analyzed, seeking to identify the interpretive currents and administrative precedents regarding the use of PIS and COFINS credits in transfer freight. This documentary analysis allowed us to map the divergences between the administrative and judicial spheres.

Complementarily, doctrinal currents that address the concept of input and the non-cumulativeness of social contributions were consulted. Authors such as Braghini (2018), Cruz (2022), Paulsen and Velloso (2025), and Pêgas (2018) were used to build the theoretical and legal framework that supports the discussion on credit appropriation.

The data analysis technique employed was the application of the “subtraction test”, developed in Special Appeal No. 1.221.170-PR. This test consisted of a methodological exercise to verify whether the suppression of the freight transfer service would compromise the development of the company’s economic activity or the quality, viability, and commercialization of the products.

The analysis sought to describe the potential of utilizing PIS and COFINS credits, considering the essentiality and relevance of transfer freight for the company’s core business. The aim was to support tax management decisions, fiscal risk mitigation, and tax planning in the agricultural inputs sector, in light of jurisprudence and administrative practice.

No primary data collection was carried out through questionnaires, interviews, or direct observation of participants. The research focused on the interpretation and application of the legal and doctrinal framework to a specific business scenario, using publicly available information and documentary data from the company, without access to confidential individual information.

Regarding ethical considerations, as this is a study of a documentary and jurisprudential nature, there was no direct involvement of human beings as research participants. Therefore, the application of an Informed Consent Form (TCLE) was waived. The confidentiality of the studied company’s information was preserved, focusing on operational and tax aspects in a generic manner.

3. Results and Discussion

The analysis of the potential for utilizing PIS and COFINS credits on freight for the transfer of goods between establishments of the same taxpayer, in the agricultural inputs sector, revealed a complex scenario, marked by interpretative divergences and operational specificities. The research demonstrated that transfer freight, in this context, transcends the nature of a mere administrative or logistical act, configuring itself as an essential and relevant element for economic activity, the absence of which makes commercialization and revenue generation unfeasible.

On the Influence of Interpretive Currents in Tax Management

The investigation identified two predominant interpretative currents that influence tax management: the constitutionalist and the legalist. The constitutionalist current, mostly defended by the Brazilian judiciary, favors the crediting of any expenses that contribute to wealth production and the achievement of the taxpayer’s activity (Pêgas, 2018). This view adopts a broader perspective of the concept of input, focusing on the economic function of the expenditure.

In contrast, the legalistic current, predominant in administrative courts, is based on a more restrictive interpretation of the norm. According to this approach, the PIS and COFINS credit is only allowed when there is explicit mention of the factual situation in the legislation, limiting the concept of input to the physical incorporation of the good into the finished product. This divergence generates an environment of legal uncertainty for companies, requiring cautious and well-founded tax management.

From the Understanding Reached by the Superior Court of Justice

The Superior Court of Justice (STJ), through Special Appeal No. 1.221.170-PR, established a crucial interpretative milestone for the concept of input in the non-cumulative regime of PIS and COFINS. The established understanding emphasizes that input must be understood in light of the criteria of essentiality and relevance for the taxpayer’s economic activity, rejecting the restrictive interpretation that required the physical incorporation of the asset into the final product. This thesis, reported by Napoleão Nunes Maia (2018), highlights that the object of these contributions is revenue, that is, the capacity to generate wealth.

To apply the criteria of essentiality and relevance, the STJ introduced the “subtraction test”. This test consists of verifying whether the exclusion of a certain good or service from the production chain would compromise the taxpayer’s economic activity or the quality, viability, and commercialization of the final product. If the suppression makes the core activity unfeasible or significantly impairs it, the good or service is considered an input, legitimizing the use of the credit.

From the Understanding Reached by the Administrative Council of Tax Appeals

Within the scope of the Administrative Council for Tax Appeals (CARF), administrative jurisprudence, although formally recognizing the STJ’s thesis, demonstrates resistance in the concrete application of the expanded concept of input. A decisional line prevails that frequently denies the right to credit in situations of internal transfers, classifying them as merely logistical or operational acts, without immediate revenue generation.

However, rulings and dissenting votes were identified at CARF that adopt a more favorable view towards the crediting of transfer freight in the agrochemical sector. For example, Ruling No. 9303-015.249 (CARF, 2024) allowed credit upon proof of the burden of the debt via Electronic Transport Document (CT-e) and Electronic Service Invoice (NFS-e), demonstrating the practical application of the subtraction test. Other judgments, such as Ruling No. 3302-014.630 (CARF, 2024), recognized the essentiality of freight in enabling commercialization in distant regions and ensuring the integrity of the goods, aligning with the view that the expenditure is indispensable in the production chain.

The analysis of tax management reveals that, to sustain the utilization of credits, the company must present robust fiscal documents, contracts, and sales orders. In cases of limited corporate purpose, the CARF tends to be the most restrictive body, requiring the formation of provisioned capital to mitigate fiscal risks. For a broad corporate purpose, however, the risk of credit disallowance is higher, with the managerial implication of an insufficient demonstration of essentiality and relevance, as observed in decisions of higher courts.

From the Understanding Established by Doctrine

The doctrine, in convergence with judicial understanding, sustains the possibility of PIS and COFINS credit on expenses for transport services for the transfer of goods. Paulsen and Velloso (2025) and Pêgas (2018) argue that the non-cumulative regime of these contributions differs from ICMS, as it is based on expenses with goods and services that are functional to the economic activity, and not on the tax debited in a previous operation. Credit is due when the good or service is a functional element that allows the business to “function”, exist, persist with original qualities or enhance new qualities, contributing to the continuous production of wealth.

Of the Non-Cumulative Regime of PIS and COFINS

The non-cumulative regime of PIS and COFINS, based on Art. 195, §12 of the 1988 Federal Constitution and implemented by Laws nº 10.637/2002 and nº 10.833/2003, differs from the ICMS system. While ICMS adopts a non-cumulative system of a financial nature, PIS and COFINS operate under a non-cumulative system of an economic nature, focused on expenditures necessary for business activity. Gross revenue is the central taxable event, and all stages of the production and commercial process must be analyzed for their contribution to achieving this economic result. The non-cumulative system aims to preserve the neutrality of contributions, preventing essential costs from burdening wealth generation.

From the Concept of Input in PIS and COFINS

Historically, the concept of input for PIS and COFINS was not clearly defined, generating debates. Initially, the administrative interpretation was restrictive, similar to that of IPI, limiting inputs to goods physically incorporated into the final product. However, the Judiciary and legal doctrine gradually moved away from this view, favoring the economic function of the good or service in the production chain. Special Appeal No. 1.221.170-PR from the STJ consolidated the understanding that input is any good or service essential and relevant to the core activity, even if it is not physically incorporated into the product, requiring a concrete assessment of the role played in revenue generation.

The subtraction test, as a practical methodology, allows verifying whether the suppression of a good or service would compromise economic activity or product commercialization. In the agricultural inputs sector, applying this test is crucial, as the absence of adequate transportation makes the supply of distribution centers and regionalized service unfeasible, eliminating final sales and, consequently, the object of PIS and COFINS taxation. This demonstrates that freight is not a mere convenience, but a necessary condition for the continuity of economic activity and the generation of taxable revenue.

Logistics in the Agricultural Inputs Sector

The agricultural inputs sector has unique economic and regulatory characteristics, with strong dependence on logistical predictability and distribution capillarity. The demand for pesticides and fertilizers is directly linked to production cycles and climatic conditions, making delivery agility a critical factor. Logistics, in this context, assumes a strategic role, as late delivery can make wealth generation unfeasible for all parties involved, as pointed out in the introduction.

The ICMS Agreement No. 100/97, although focused on ICMS, influences the sector’s logistics by granting tax benefits that stimulate production and distribution on a national scale. This encourages the creation of distribution centers and, consequently, the performance of transfers between establishments of the same taxpayer, which become necessary steps for enabling sales. Tax management must, therefore, analyze these operations from the perspective of their economic function, and not just formal.

The transport of chemicals and potentially harmful products, such as pesticides and fertilizers, is governed by strict regulations from the National Land Transport Agency (ANTT) and the Ministry of Agriculture and Livestock (MAPA). Resolutions such as ANTT No. 5.998/2022, 6.016/2023, and 6.056/2024, and Law No. 14.785/2023, impose technical requirements for vehicles, drivers, and safety procedures. Non-compliance with these regulations leads to severe penalties and compromises the logistics chain, demonstrating that specialized transport is a *sine qua non* condition for the commercialization of products, not a managerial option.

From the Transfer between Establishments of the Same Contributor

The transfer of goods between establishments of the same taxpayer is an intragroup asset movement that, legally, does not generate immediate revenue nor constitutes a mercantile operation. Accounting-wise, it represents a reallocation of inventory without altering the overall equity of the legal entity. However, functionally, this operation is an indispensable intermediate step for the realization of future sales, especially in decentralized logistics models in the agricultural sector.

The infeasibility of the transfer directly compromises the company’s ability to make sales in distant regions, affecting competitiveness and revenue generation. Thus, the transfer is not a mere internal administrative act, but a functional step in the marketing chain. Under the non-cumulative regime of PIS and COFINS, this economic function acquires legal relevance, as it evidences the causal relationship between internal movement and future revenue generation, the suppression of which would make the subsequent taxable event unfeasible.

Of Freight in the Transfer Operation as Input

The administrative view that classifies freight as a “neutral act”, dissociated from taxable revenue generation, is insufficient. In the agricultural inputs sector, freight is a functional element of the core activity, serving multiple essential functions: geographical redistribution, regulatory compliance (ANTT and MAPA), preservation of the physical-chemical characteristics of the inputs, and ensuring availability at the right time and place. The absence of this service makes the commercialization strategy and revenue generation unfeasible.

The application of the subtraction test to transfer freight demonstrates its essentiality. The suppression of this service makes commercialization unfeasible, especially considering the “economic perishability” of inputs, where the product’s value is lost if not delivered at the right time. Weather conditions and the temporal windows for input application reinforce this essentiality, as logistical delays can result in lost sales and revenue. Freight, therefore, acts as a climate and commercial risk mitigator, being a strategic component for revenue generation.

From the Critical Analysis of Administrative Jurisprudence

Normative Opinion RFB No. 05/2018, while acknowledging the STJ’s criteria of essentiality and relevance, adopts a restrictive application for intermediate services, such as freight forwarding. The Brazilian Federal Revenue Service understands that the absence of immediate invoicing in the transfer discredits the causal relationship with taxable revenue, methodologically limiting the subtraction test to a formal verification. This approach fragments the economic chain and ignores the operational reality of the sectors.

At the CARF, the majority line of decision aligns with the Federal Revenue, denying credits on transfer freight based on the premise that they are internal acts without earned revenue. However, the existence of favorable rulings and dissenting votes demonstrates that administrative jurisprudence is not monolithic. These minority decisions, considering operational reality, logistical structure, and sector peculiarities, analyze freight as a functional stage integrated into the commercialization chain, showing that a consistent economic analysis and adequate documentation can find receptivity.

The Tax Management Perspective

The decision-making regarding the utilization of PIS and COFINS credits on transfer freight occurs in an environment of legal uncertainty, due to the divergence between the judiciary and the tax administration. Tax management must, therefore, conduct a structured technical assessment, considering the legal adherence of the thesis, the robustness of the documentation, the company’s operational context, and risk appetite. Non-cumulativeness requires an active role from the manager in interpreting and applying the law, avoiding both excessive conservatism and aggressive practices without technical backing.

Tax documentation, traceability, and governance are central elements for supporting the utilization of credits. Logistics contracts, electronic freight documents (CT-e), transfer invoices, inventory records, and evidence of regulatory compliance (ANTT and MAPA) are crucial. The integration of this information demonstrates that freight is a functional stage of the revenue generation chain, not a merely administrative expense. Tax governance practices, with internal procedures and periodic review, mitigate risks and strengthen the company’s position in potential litigation.

The measurement of fiscal risk and the constitution of accounting provisions are indispensable. Interpretative divergence imposes on the manager the duty to measure the probability of questioning and the financial impacts of an eventual disallowance. The accounting provision is a prudential instrument that neutralizes financial impacts, allowing the company to exercise its right to credit without compromising budgetary predictability. This approach, which considers the volume of credits, technical foundation, and fiscal history, reflects a responsible and strategic stance of tax management.

Responsible tax planning in the agro-industrial sector recognizes transfer freight as an input, based on the systematic interpretation of the legal system and the operational reality of the sector. This is not an artificial expansion of credit, but a coherent application of the non-cumulative regime to the specificities of a regulated and time-sensitive production chain. Tax management, by adopting this approach, contributes to the economic neutrality of social contributions, avoiding the cumulativeness of essential costs and strengthening the alignment between business strategy, compliance, and tax efficiency.

The utilization of PIS and COFINS credits on transfer freight generates significant managerial impacts. The reduction in the effective tax burden and lower tax disbursement improve cash flow. Increased documentation and control of operations strengthen compliance and enhance tax governance. Technical analysis of credits mitigates fiscal risks, and the resulting fiscal efficiency contributes to greater business competitiveness. These impacts demonstrate that credit management transcends the legal sphere, reaching aspects of management, compliance, governance, and financial sustainability.

Law No. 10.925/2004 and the Impacts of Complementary Law No. 224/2025 on the Agricultural Inputs Sector

Law No. 10.925/2004 established a differentiated tax regime for agricultural inputs, applying a zero rate of PIS and COFINS on specific operations to reduce production costs. However, Complementary Law No. 224/2025 (2025) promoted the linear reduction of these incentives, gradually reintroducing the contributions. This change, which implies an impact of 0.925% on the sale of inputs from 2026 onwards, increases production and marketing costs, making the correct identification and utilization of credits even more essential to mitigate the financial impact of the additional tax burden.

From Complementary Law No. 214/2025 and the Transition to the New Consumption Taxation Model

Complementary Law No. 214/2025 (2025) establishes the progressive extinction of PIS and COFINS starting January 1, 2027, replacing them with the Contribution on Goods and Services (CBS). This transition represents a structural change in consumption taxation in Brazil. In the current context, the administrative restriction on PIS and COFINS credits for transfer freight will likely persist until the regime’s extinction, given the regulatory prioritization in implementing the new system.

Starting in 2027, the legal discussion tends to shift towards the recovery of credits not utilized during the PIS and COFINS validity period (2022-2026), considering the five-year statute of limitations. The expectation is that the CBS will adopt full non-cumulativeness, allowing the crediting of any material for industrial and productive use. This perspective reinforces the importance of robust documentation, traceability of operations, and correct measurement of potentially recoverable amounts for the success of future legal actions.

In summary, the study demonstrated that hiring freight for the transfer of goods in the agricultural input sector meets the criteria of essentiality and relevance, legitimizing the PIS and COFINS credit. This conclusion is based on the application of the subtraction test, which reveals the unviability of commercialization without transport, and on the analysis of the sector’s regulatory and logistical specificities. Tax management, in this scenario, must adopt technical criteria, robust documentation, and prudential measurement of fiscal risk to optimize efficiency and strengthen governance, especially in the face of legislative changes and the transition to the new consumption tax model.

4. Conclusion

This study described the potential of utilizing PIS and COFINS credits levied on the hiring of freight for the transfer of goods between establishments of the same taxpayer, focusing on the agricultural inputs sector. It was verified that transfer freight, in this context, is not configured as a mere administrative or logistical act, but as an essential and relevant element for economic activity, the absence of which makes commercialization and revenue generation unfeasible. The application of the “subtraction test” by the Superior Court of Justice confirmed the essentiality of the service, demonstrating that its suppression breaks the causal chain that culminates in taxable revenue. An interpretative divergence was identified between the broader view of the judiciary and the restrictive approach of the tax administration, which frequently disregards the economic function of freight in the production chain. Logistics in the agricultural sector, heavily regulated and sensitive to factors such as climate conditions and application deadlines, was recognized as an indispensable structural component for product commercialization. Thus, the work contributed to substantiating the secure appropriation of credits, the mitigation of tax risks, and tax planning, promoting greater tax efficiency and strengthening the tax governance of companies in the sector.

However, a limitation of the study was recognized as the concentration on a specific sector of the economy and the dependence on jurisprudential interpretation still controversial in the administrative sphere, which imposes on tax management the need to adopt rigorous technical criteria, robust documentation, and prudent measurement of fiscal risk. Recent legislative changes, such as Complementary Law nº 224/2025, which reduced tax incentives, and Complementary Law nº 214/2025, which establishes the transition to the Goods and Services Tax (CBS) from 2027, intensify the relevance of correct credit management. In this changing scenario, the discussion about the use of PIS and COFINS credits tends to shift to the recovery of amounts not recognized in the final period of validity of these contributions (2022-2026). It is suggested that future studies explore the implications of the full non-cumulativeness of the CBS and the redefinition of the role of credits in the new consumption tax system, as well as the effectiveness of credit recovery strategies in the post-PIS/COFINS context.

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Article originating from the Final Course Work of the Specialization in Tax Management of the MBA USP/Esalq

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