What is the deadline for filing the EFD-Reinf?

The EFD-Reinf must be filed with the Sped system on a monthly basis by the 15th day of the month following that to which the accounting records relate. Companies promoting sporting events, on the other hand, must submit their records within two working days of the event taking place.

With the publication of RFB Normative Ruling No. 2,163/2023, whenever the filing deadline falls on a non-business day for tax purposes, the corresponding submission will be postponed to the following business day.

Thus, the first submission covering R-4000 information for events taking place from September 1, 2023, must be made by October 16, as October 15 falls on a Sunday.

What EFD-Reinf changes will take effect as of September 2023?

The R-4000 series comes into effect for withholding tax invoices pertaining to:

• Withholding Income Tax (IRRF);
• Social Integration Program (PIS) / Public Service Employee Savings Program (Pasep);
• Contribution for Social Security Financing (Cofins);
• Social Contribution on Net Income (CSLL).

The withholding taxes above will be added to list of retentions that must be reported through the EFD-Reinf, which already includes the withholding of contributions payable to the Social Security Administration (INSS).

As with the eSocial, information reported through the EFD-Reinf is automatically entered into the DCTFWeb. The tax authorities' system receives the data, calculates the amounts payable and, only after the DCTFWeb has been filed is it possible to issue the corresponding payment slip for all these taxes, by generating a federal revenue payment form - Darf. 

At the moment, taxes are withheld using separate forms. Starting September, with the inclusion of the R-4000 series in the EFD-Reinf, all such retentions will be consolidated into a single Darf issued via DCTFWeb. This means that, in a way, taxpayers will have to be extra mindful of the accuracy of the information supplied. Any rectification will require both forms to be amended and might lead to potential penalties.

Another aspect that warrants attention concerns registration data, as changes will be made to the codes used to report the nature of income. This is bound to affect management software and controls, so businesses must adjust their tools to the new situation.

In other words, companies must make the necessary adjustments to provide Income Tax and social contribution information on a monthly basis to their accountants or directly to the tax authorities, as appropriate. Priority should be given to the quality of the data supplied in order to prevent risks and tax liabilities.

It is worth noting that companies will still be required to file the Dirf in 2024 to report information pertaining to the calendar year 2023 (2023 tax base to be checked against data submitted via EFD-Reinf in the same year). This requirement ends in 2025. Read more here.

How to prepare your business?

Based on the understanding that the flow of tax information is becoming faster and that inspections will be more rigorous, taxpayers should:

Make internal adjustments to provide accounting and tax information in a more agile manner;
• Promote a change in the company culture to operate in line with the new requirements, both in terms of deadlines and information accuracy;
• Adjust their systems so they can make correct classifications;
• Work in conjunction with their accounting partners during this transitional stage to adapt to the new rules.

Partnership for a secure transition

DPC has been working on systemic improvements and is making the adjustments to the relevant processes to ensure a sound transition for its clients while ensuring their compliance.

In addition to its accounting and tax departments, DPC has a team dedicated to system parameterization, which is able to assess their customers’ needs and make the necessary adjustments to their ERP of choice to ensure good standing with the new requirements. Contact us at: dpc@dpc.com.br.