DCTFWeb: a link between eSocial and EFD-Reinf

The DCTFWeb (Statement of Debits and Credits Federal Social Security Tax and Other Entities and Funds) is the new RFB feature intended to replace the FGTS Payment Slip and Information to Social Security - GFIP.

The measure keeps the tax withholding rules, but influences on how to state the information on obligations. With the methodology change, companies are forced to reassess their processes, document flow and globally tax practices.

The presentation of a new electronic tax document is an obligatory added to eSocial and EFD-Reinf, imposing a new work structure. A proper deployment of these last two processes is fundamental to the DCTFWeb project success as well.

As has been widely publicized, the Treasury has been equipping to promote an even more fast and efficient data cross-checks. This puts the business in Brazil before a new moment, in which administrative routines and business cultures must be rethought.

DCTF x DCTFWeb

The DCTF provides statement of non-social security debt. Firstly, DCTFWeb should cover the statements of social security and other entities and funds federal tax debts and credits.

How it works

The DCTFWeb system is supplied by the information sent to eSocial and EFD-Reinf, where, after their respective closing events, DCTFWeb receives this data and generates a statement containing debits (discounts, employer contribution and other entities and funds, etc.) and credits (discounts of child benefit, maternity pay and withholdings on invoices), consolidating the information and calculating the corresponding INSS.

Before deployment of the DCTFWeb, the taxpayer stated social security contributions through GFIP, a payment slip that allowed the manual data inclusion and changing.

Now, debits (social security and other entities contributions) are automatically generated from information extracted from eSocial or EFD-Reinf. The credits (child benefit, maternity-pay, and withholdings on invoices) can be generated from eSocial or EFD-Reinf or imported from the RFB systems. It is also possible to manually register the credits, such as inclusions, exclusions, suspensions, installments and offsetting.

For DCTFWeb transmission, as already occurs with eSocial and EFD-Reinf, among other obligations from SPED environment, it is important to use a security certificate issued by an entity accredited by ICP-Brasil, except for micro and small enterprises within the Simples Nacional that have up to one employee in the statement reference period and for the individual micro entrepreneurs, who should use the access code.

After transmitting the statement, the payment slip (DARF) will be issued, which will be electronic and barcoded.

Presentation requirement

• Initially, DCTFWeb is mandatory for companies that earned revenues greater than BRL 78 million in 2016 calendar year. These taxpayers will be required to file DCTFWeb, replacing GFIP, as of August 2018, by September 15, 2018.

• For other companies, the requirement enters into force on January 1, 2019.

• Public agencies should file the statement as of July 1, 2019.

• Immune and exempt legal entities must comply with the deadline January 1, 2019, even if they have earned revenues greater than BRL 78 million.

Find at RFB Normative Instruction No. 1787 the complete list of rules.

Deadlines

DCTFWeb monthly: Presentation by the 15th of the month following the taxable event occurrence (payroll, services invoice subject to social security withholding, commercialization of rural production, etc.), when the term is anticipated for the immediately preceding business day.

DCTFWeb yearly: It must be sent by the 20th of December for 13th salary information.

DCTFWeb daily: Presentation by the second business day of the month following the sports event by the entity promoting the show.

It is worth mentioning that, if there is no taxable event, the taxpayer must present the DCTFWeb stating a "no turnover" in the first month in which the situation occurs. Staying in this condition, one must yearly present the statement, always in January.

DPC’s challenges and solutions

DPC has been working on adapting to eSocial, EFD-Reinf and DCTFWeb, either in the individual treatment of each obligation per company or in consolidating all data. Experience with systems has been showing the importance of working with accurate information.

As an EFD-Reinf influence, the DIRF, which was yearly, is now monthly informed, imposing a need for adaptation and a new work pace for companies. Although its discontinuity is mentioned, there is still no definite term for the DIRF extinction.

The registrations adjustment for client and supplier, according to the correct service and withholding codes is also among the challenges. This should be very well adjusted between the involved parties so that there are no inconsistencies during the information mesh matching. Thus, the service code adopted by a client must be the same as the contracting company uses.

For DCTFWeb, it is necessary to check the data with the information provided in eSocial and EFD-Reinf before filing the statement. Domingues e Pinho Contadores has a team specialized in validating information and, in case of credits, DPC analyzes and records information that can be manually bound, ensuring the correct offsetting of debits and credits, thus avoiding further penalties.

Although much is discussed about simplification of processes with the taxes authorities brought by the systems, the reality of this moment of transition is to increase the demand for labor. The challenge pass through a need to adapt internally companies through the process of systemic validation and registration consistencies checking, in addition to the accumulation of obligations for cases in which the new presentation form has not yet resulted in the old requirement extinction.

DPC’s specialists have been advising companies of different sizes and lines of action to meet the requirements, both in a timely and periodic manner. Customized training, evaluation of the company's stage for response to systems, alignments to address cadastral inconsistencies, parameterizations, validations, and tests in pre-production/approval environments are some processes for which taxpayers can count on specialist’s support who work with an integrated view of the new tax situation.