On the subject in question, initially reported in a statement (link) from 08.21.2013 our opinion ba

On the subject in question, initially reported in a statement (link) from 08.21.2013 our opinion based on single query solution (link) existing at the time, which was our understanding in the sense that the Brazilian Cargo Agent would responsible for launching the services of international freight in SISCOSERV system, except in cases of incoterms starting with C and D (CPT, CIF, CIP, CFR, DAT, DAP) where this issue would not be necessary in our opinion, on that occasion. This view reflected the constant in the query solution 106/2013 (link) published on 03/07/2013.
However, on 10.09.2013 was published the Joint Ordinance RFB / SCS 1284/2013 of 09.09.2013 (link) with version 6 of the manual system (link), we hoped could clarify all issues relating strand aerospace to the launch of international freight in SISCOSERV. But besides not clarify the issues, apparently was at odds with the aforementioned query solution 106/2013 strand aerospace (link). Due to the fact that information on legislation definitely WERE NOT CLEAR, allowing different interpretations, we reported that we could not place us safely over who would RESPONSIBLE strand aerospace FOR LAUNCH OF "RAS" and "RP" NO SISCOSERV, if the service import freight there is a freight brokering agent for a Brazilian cargo. That's because the manual 6 brought news in your text, compared to 5. version of the manual, stating in his text, that although subcontracting occurs resident or domiciled in Brazil or abroad, release should be done by the Brazilian company that maintains a contractual relationship with the company abroad for the service. Ie the 6th manual was the clear inclusion of the hypothesis of a Brazilian company or subcontracting abroad not interfere in charge of the registry in SISCOSERV, which was not considered in the query solution that initially we rely. So, we had recommended to consult the legal dept of the company to decide who would be responsible for launching with this new information, the importer / exporter or freight forwarder in Brazil.
However, on 31/10/2013, unfortunately the last date for the launch of these services in SISCOSERV, was published the 7th version of the procurement manual (link), strand aerospace through the Joint Ordinance RFB / SCS 1534/2013 (link). This new version of the manual has brought the question of exactly NEWS responsible for launching. Changing the text in this new version has determined that for the definition of the charge of the registry in the system, strand aerospace beyond the contractual relationship that should exist between the Brazilian company and the overseas company for the service, the company MUST BILL abroad strand aerospace by Brazilian company provision of this service.
This new element (billing service by the company abroad against the Brazilian company) really strand aerospace can change the concepts and make the query solution is no longer in apparent contradiction with the current 7th manual acquisition. In this version of the manual, including examples strand aerospace that seem to support the understanding stated strand aerospace in the query solution were presented.
Thus, due to the complexity of the matter and due to constant changes in legislation that seems to change the concept of the responsibility for the initiation, again we recommend you consult your legal dept of companies so that they are positioned on WHO IS RESPONSIBLE FOR THE LAUNCH OF DATA SISCOSERV IN THE EVENT INTERNATIONAL FREIGHT CARRIED THROUGH A FREIGHT IN BRAZIL.
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