According to a decision issued by the 3rd Panel of the Superior Chamber of the Administrative Council of Tax Appeals (CARF), the crediting of PIS and COFINS is permitted on expenses with freight for inputs and semi-finished products that are transported between establishments of the same company.
The case analyzed was related to the freight transportation of raw materials from a mining company, for the production of fertilizers and chemical products, in which the understanding remained that the transfer of this raw material from mines to the industry is essential to the production process, and that the expenses with freight of the input generate PIS and COFINS credits, fulfilling the criteria of essentiality and relevance, as decided by the Superior Court of Justice (STJ).
