Tributologia # 305 - CARF barra crédito de PIS/Cofins em publicidade digital: “insumo” tem limite

The CARF (Administrative Council of Tax Appeals) denied the use of PIS/Cofins credits related to Renner's expenses on digital advertising, concluding that the activity cannot be treated as an input. In this episode, I explain what this interpretation signals for retail and marketing-intensive companies, despite STJ (Superior Court of Justice) ruling 779: where the CARF is drawing the line between commercial strategy and essential/relevant input, what criteria usually weigh in the judgment (link to the core business, indispensability, and materiality of the expense), and how this impacts credit governance, from accounting classification to the evidentiary dossier. I conclude with practical recommendations to reduce risk in audits and litigation: documentation, economic rationale, and "essentiality" tests before claiming credits. (Case No. 11000.724636/2021-08)