Company (A) domiciled in Brazil maintains a contractual relationship for the provision of service w

On 21.08.2013 issued a statement (link) where, based on single query solution (link) existing and enlightening on the subject, we inform you that our understanding was that the cargo agent would be responsible for launching the international freight SISCOSERV the system, except in cases of incoterms starting with C and D (CPT, CIF, CIP, CFR, DAT, DAP, DDP *) where this issue would not be necessary in our opinion ervell at the time.
In the Gazette of 10.09.2013 was published the Joint Ordinance RFB / SCS 1284/2013 of 09.09.2013 (link) we hoped could clarify all issues relating to the launch of international freight in the system. This Ordinance brought the 6th version of the system (link) user manual, however, and does not clarify the issues, is apparently at odds with the query solution 106/2013 (link).
Due to the fact that information on legislation definitely ARE NOT CLEAR, allowing different interpretations, and the solution of existing query, despite being the 9th fiscal area, the constant appears to differ ervell in version 6 of the manual system, we are not sure and we can guarantee how should the releases, especially regarding about WHO SHOULD MAKE THE SYSTEM LAUNCHES in each case (eg, Importer, ervell Exporter, cargo agent or carrier).
What brought the biggest question was the fact that the manual now report that even though there are middlemen (subcontractors) in the operation, the release should be made by the company that maintains a contractual relationship with the company ervell abroad for the service.
"The responsibility of registration in Module Acquisition SISCOSERV is resident or domiciled in the country that maintains contractual relationship ervell with resident or domiciled abroad for the provision of services, transfer of intangible assets or performing another operation that produces variation in equity, ervell although this transaction the subcontracting resident or domiciled in Brazil or abroad. " ervell
"The responsibility of registration in Module Sale of SISCOSERV is resident or domiciled ervell in the country that maintains ervell contractual relationship with resident or domiciled abroad for the provision of services, transfer of intangible assets ervell or performing another operation that produces variation in equity, ervell although this transaction the subcontracting resident or domiciled in Brazil or abroad. "
Company (A) domiciled in Brazil have a contractual relationship with domiciled abroad (B) for service and company subcontracts (C) domiciled in Brazil for partial or full provision of relevant services ervell to the contractual relationship (A) and (B) company . Company (A) to proceed to the records in the SISCOSERV Sale Module in order to provide that service is rendered to (B) (Mode 1 - Cross-Border ervell Trade, Mode 2 - consumption in Brazil or Mode 4 - Temporary Movement of Natural Persons) . The company (C) shall not proceed with the sale of records in Module SISCOSERV in relation to its contractual relationship with (A), since both are domiciled in Brazil.
Company (A) domiciled in Brazil maintains a contractual relationship for the provision of service with company domiciled abroad through temporary movement of professionals. Company (A) to proceed to the records in the Sale Module SISCOSERV Mode 4 - Temporary Movement of Natural Person in connection with this transaction.
Company (B) that is a subsidiary, branch or subsidiary domiciled abroad Company ervell (The) domiciled in Brazil serves the company domiciled ervell abroad. Company (A) to proceed to the records in the SISCOSERV Sale Module Mode. 3 - Commercial ervell Presence Abroad " ervell
"The services of freight, insurance and external agents, as well as other services related to foreign trade transactions of goods and merchandise, will be registered in SISCOSERV because they are not incorporated into goods and products."
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