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Sector · Multi-state manufacturing

Manufacturing with plants in several states: ICMS, ST and credit that balance across the plants

When one company produces in two or more states, every transfer, every input under tax substitution (ST) and every fixed asset follows a rule with two sides. ICMS is Brazil's state value-added tax. The tax team sees the problem months later, in a credit that one plant takes and the other does not accept.

This page gathers the law read in official sources, the obligations of the sector and the SAP setup points that most often fail. The tax decision belongs to the client. Our job is to design the setup, configure it in SAP and deliver proof that it works.

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Tax map

What weighs in multi-state manufacturing, tax by tax

The direct answer

Since 2024, a transfer between plants of the same owner is not a taxable event for ICMS, but credit, ST, DIFAL, Block K and the FCI still need their own rule for each pair of states.

To start the conversation: does the transfer invoice between your plants leave without ICMS shown on every route, and does the entry credit at the destination match what SAP calculated?

The short answer: if it matches, the route is right. If any route leaves with tax shown or the credit differs, the starting point is the route matrix by pair of states, tested on the invoices of one month.

TaxThe rule that hits the sector mostLegal basis readWhere it usually breaks
ICMS on transfers between plantsAn output to an establishment of the same owner is not a taxable event. The credit from earlier operations is kept, and on an interstate transfer the destination secures a credit limited to the interstate rate on the transferred value.LC 87, art. 12 §4; LC 204/2023; STF, ADC 49Transfer invoice with ICMS shown as if it were a sale.
ICMS-STIt depends on an agreement between the states (each one a UF) and applies by NCM and CEST. Unless the rule says otherwise, it does not apply to a transfer between establishments of the sender (except to a retailer) or to raw material sent to an industrial company that does not sell the same good.LC 87, arts. 6 to 10; Conv. ICMS 142/18, clauses second and ninthThe same ST setup copied to all plants, without the exception of the destination state.
DIFALIt covers the sale to a final consumer who is not a taxpayer in another state (due from the sender) and the entry of a good for use, consumption or fixed assets by a taxpayer (due from the recipient).EC 87/2015; LC 190/2022; Conv. ICMS 236/21; LC 87, art. 12 XVApplying DIFAL to every route between plants, or forgetting the one on assets and consumption.
4% rate and FCIA good that is imported, or that has an import content above 40% after processing, leaves in an interstate operation at 4%. There are exceptions: no national equivalent, basic production process and natural gas.Conv. ICMS 38/13, clauses second to fourthOutdated import content and the wrong rate on the invoice.
IPIThe industrial company pays on the output of the product and can take credit on raw material, intermediate product, packaging and returned products.RIPI (Decree 7.212/2010), arts. 24, 35, 226 and 229; TIPI (Decree 11.158/2022)NCM different from the TIPI and credit with no support.
PIS and CofinsNon-cumulative regime, with credit on goods and services used as inputs in production.Art. 3 of the non-cumulative PIS law (10.637/2002) and of the Cofins law (10.833/2003)Input with no credit rule by plant and by operation.
CIAPThe ICMS credit on permanent assets is taken in 48 monthly installments, multiplied by the share of taxed outputs and exports.LC 87, art. 20 §5; Ajuste SINIEF 02/09, clause third §5Asset transferred between plants without the record of the factor and the balance.
IBS, CBS and ISIn 2026 the test rates are IBS at 0.1% and CBS at 0.9%, but whoever meets the ancillary obligations is exempt from paying (art. 348, § 1), and PIS and Cofins stay in full. IPI goes to zero in 2027, except for products with incentivized industrialization in the Manaus Free Trade Zone, and ICMS falls from 2029 to 2032 and ends in 2033.EC 132/2023 (ADCT, arts. 126 to 129); LC 214/2025, arts. 343 to 348Two credit regimes living together during the transition.
Index

Choose your entry point by role

Four entries, one for each role, straight to the block that answers your question.

01Tax and fiscal

Transfer and ST between plants: what the law and the STF have already decided.

Go to the section

02IT and SAP integrator

Eight setup points that often fail between plants.

Go to the section

03Management and decision

Where the tax process becomes a project in industry.

Go to the section

04Production and Block K

Block K record by record: what production must feed.

Go to the section
Direct links
Direct links:tax mapobligationsreformcapital goods and incentiveslaws readhow DFSpro steps inquestionswhere to start
Between plants

Transfer and ST between plants: what the law and the STF have already decided

Four milestones, all read in official sources, now define ICMS on the movement between establishments of the same owner.

ADC 49, April 2021

The STF plenary ruled the action unfounded and declared unconstitutional the parts of LC 87 that provided for ICMS on transfers between establishments of the same taxpayer: art. 11 §3 II, art. 12 I and art. 13 §4.

Modulation, April 2023

The STF decided that non-incidence applies from the 2024 tax year, except for cases pending until the record of 29/04/2021, to protect operations and structures already used by taxpayers.

LC 204, December 2023

It bars ICMS on the output to an establishment of the same ownership, keeps the earlier credit and allows the taxpayer, by option, to treat the transfer as a taxed operation. It applies since January 1, 2024.

Theme 1367, February 2025

In RE 1490708, with general repercussion, the STF confirmed unanimously that non-incidence applies only from 2024, with the same exception for cases pending until 29/04/2021.

How ICMS Agreement 142/18 organizes ST

Agreement between the states

ST in an interstate operation depends on a specific agreement between the states involved, and the destination state may require its own act of the Executive Branch to bring it into its rules (clause second).

Identifying the item

Each good under ST appears in one of Annexes II to XXVI, with NCM and CEST. The invoice reports the CEST even when the operation is not under ST (clause twentieth).

Law of the destination

Whoever withholds follows the rule of the state where the good will be sold (clause fourth). The amount to pay is the tax at the internal rate of the destination on the ST base, minus the tax on the own operation (clause thirteenth).

Refund and ancillary returns

The refund of withheld ST can be made by an exclusive NF-e, at the discretion of the taxpayer's state (clause fifteenth). The substitute files the GIA/ST, or the DeSTDA if it is in the Simples regime, with the destination state (clause twenty-first).

Official source, read on 19/10/2026

Clause ninth of ICMS Agreement 142/18, unless the rule says otherwise: ST does not apply to a shipment to an industrial establishment that produces the same good. It also does not apply to an interstate transfer between establishments of the sender, unless the recipient is a retailer. And it does not apply to a shipment to an industrial company of raw material, intermediate product or packaging, as long as it does not sell the same good. Paragraph 1 allows the destination state not to apply the regime between interdependent companies, unless the recipient is a retailer.

DFSpro judgment

Because each destination state may bring the agreement into its rules in its own way, the right ST rule for plant A does not hold alone for plant B. The matrix of exceptions by pair of states must exist and be proven in SAP.

Law

Sector rules, with status and source read between 19/10/2026 and 22/10/2026

Each line was opened in the official source, on the dates shown in the sources section, which gives the address of each one.

RuleSubjectStatus
Complementary Law 87/1996 (Kandir Law)ICMS, ST (arts. 6 to 10), credit (art. 20), CIAP and use and consumption (art. 33)In force, amended. Credit on use and consumption from 01/01/2033 (art. 33 I)
Complementary Law 204/2023Bars ICMS on a transfer between establishments of the same ownerIn force since 01/01/2024
Complementary Law 190/2022DIFAL on an operation to a final consumer who is not a taxpayerIn force. Practical start of effects: not checked
Constitutional Amendment 87/2015DIFAL: difference between the internal and interstate rate, paid to the state of the recipientIn force
ICMS Agreement 142/18ST and advance-payment regimes that close the taxation; CEST; GIA/STIn force, amended (last change listed: Conv. ICMS 107/26)
ICMS Agreements 52/17 and 92/15General rules on ST and CEST, before 142/18Repealed (92/15 on 01/01/2018; 52/17 on 01/01/2019)
ICMS Agreement 236/21DIFAL procedures for a final consumer who is not a taxpayerIn force, effects since 01/01/2022 by the text
ICMS Agreement 38/134% rate (Senate Resolution 13/2012) and FCIIn force, amended by Convs. 88/13 and 76/14
Ajuste SINIEF 02/09Creates the EFD; Block K; CIAP in the EFDIn force, amended (including 25/22 and 14/25)
Decree 7.212/2010 (RIPI) and Decree 11.158/2022 (TIPI)IPI regulation and tableIn force, amended. The TIPI refers to ADI 7153, not read
Non-cumulative PIS and CofinsLaws 10.637 and 10.833, with the credits of article 3 of eachIn force, amended
Constitutional Amendment 132/2023Consumption tax reform and transition (ADCT, arts. 126 to 135)In force
Complementary Law 214/2025 and 227/2026IBS, CBS, Selective Tax and Management CommitteeIn force. Law 214 was amended by 227
Law 8.248/1991, Law 13.969/2019 and Law 14.968/2024 (IT Law)Financial credit for those who invest in research, development and innovation in information and communication technology goods; Law 13.969 repealed, among others, §1-C of art. 4, and art. 11 of Law 14.968 sets the incentives in force until 31/12/2029In force, with successive wording. Percentages of art. 11 and current regulatory acts: not checked
Decree-Law 288/1967 and Constitutional Amendment 83/2014 (ADCT, art. 92-A)Manaus Free Trade Zone: IPI exemption on goods produced in the area (DL 288, art. 9) and a regime term extended by 50 years from the one in art. 92In force. Status of each article of DL 288 against LC 214: not checked
Law 11.196/2005, arts. 55 to 59PIS and Cofins rules on newsprint machines, credit for petrochemical plants and chemical industries, and petrochemical naphthaRepealed by LC 214, art. 542, XXXIV, item h. The date and the conflict with art. 57-D are on the page on chemicals and petrochemicals
STF: ADC 49 (2021), modulation (2023), Theme 1367 (2025)Non-incidence of ICMS on transfers, with effects from 2024Judged. We read the official news, not the rulings
Not checked in this round

Senate Resolution 13/2012 (only through the citation in Agreement 38/13), each ICMS Protocol on ST by segment, the list of items in the annexes of Agreement 142/18, the state deadlines for the EFD and Ajustes SINIEF 31/24 and 49/25. None of this enters here as fact.

What breaks in SAP

Eight setup points that often fail between plants

DFSpro judgment, not a measurement: it gathers the deviations between plants that appear most in our reading of configurations. Each point gives the symptom on the invoice and the test that closes it.

Transfer treated as a sale

Symptom: ICMS shown on the transfer invoice and credit at the destination plant with no pair at the origin. Proof: matching by access key between the output and the entry, with the CFOP and tax rule on each side.

Transferred credit and credit balance

Symptom: credit balance that grows at the origin and destination credit above the interstate rate on the transferred value. Proof: credit report by plant and by transfer, with the LC 204 calculation.

ST copied without the exception

Symptom: ST withheld on a shipment of raw material or on a transfer that the destination law may exclude, or a GIA/ST that does not match. Proof: exception matrix by pair of states, tested invoice by invoice.

NCM and CEST out of date

Symptom: an item that changes status in ST and leaves with too little withholding, too much, or a rejection. Proof: compare the NCM and CEST of the material master with the annex of the agreement on the date of the invoice.

DIFAL on consumption, assets and final consumer

Symptom: payment to the destination that differs from the recalculation, or DIFAL on a route that does not require it. Proof: recalculation of the difference between the internal and interstate rate on a sample of invoices by state.

Block K without support

Symptom: K230 and K235 that do not match the consumption recorded in production, or K200 different from the inventory. Proof: monthly reconciliation between production order, invoice and EFD record.

CIAP without a record

Symptom: participation index in G110 that moves with no explanation, and an asset transferred between plants with no trace of the installments. Proof: calculation record by asset, with the 48 installments and the factor of taxed outputs.

4% rate and FCI

Symptom: interstate operation with an imported input at the general rate when the import content passes 40%, or the reverse. Proof: current FCI by product against the rate that left on the invoice.

Not checked in this round

The SAP documentation on tax calculation in Brazil and on EFD generation, and the public support notes, were not read in full for this page. Nothing here states the behavior of an SAP module or note.

Ancillary obligations

What industry files and who requires it

The layout, deadline and basis of each filing are in ancillary obligations and SPED in SAP, in EFD ICMS/IPI and in the SPED law. The dates for each month are in the tax calendar.

ObligationWhat it reportsFrequency and requirement
EFD ICMS/IPIBookkeeping of ICMS and IPI, with the calculation, inventory, CIAP and production control.Monthly. Mandatory for all ICMS and/or IPI taxpayers since 01/01/2009 (Ajuste SINIEF 02/09). The deadline is set by state law, according to the EFD ICMS/IPI Practical Guide (current version: check on the SPED portal).
Block K, who files and since whenProduction, consumption of inputs and booked stock, in records K200, K230, K235 and others.Monthly, inside the EFD. Industrial establishment of a company with annual revenue of BRL 300 million or more (Ajuste SINIEF 02/09, clause third, §7, item I): stock balances since 01/2017 (CNAE 10 to 32); full bookkeeping since 01/2019 (divisions 11 and 12 and groups 291 to 293), 01/2020 (27 and 30), 01/2023 (23 and groups 294 and 295), 01/2024 (13 to 18, 22, 26, 28, 31 and 32) and 01/2025 (10, 19, 20, 21, 24 and 25). A company in the Simples Nacional regime is exempt from the block, according to the Practical Guide.
Block K, other tiersBooked stock in records K200 and K280.Company with revenue of BRL 78 million or more: stock balances since 01/2018 (item II). For the rest, item III sets stock balances since 01/2019, with full bookkeeping by a schedule still to be set (not checked). It covers the other industrial establishments, the CNAE 462 to 469 wholesalers and those treated as industrial. Each state may exempt, since 2023, the wholesaler with annual revenue below BRL 10 million (§14).
CIAP (Block G)ICMS credit on permanent assets, record G110 and its child records.Monthly, in the EFD. Bookkeeping mandatory since 01/01/2011.
GIA/ST and DeSTDAST withheld and paid to the destination state.The GIA/ST (Ajuste SINIEF 04/93) and, for a company in the Simples regime, the DeSTDA (Ajuste SINIEF 12/15), according to Agreement 142/18. Frequency: not checked.
Electronic invoiceCEST of each item, the ST base and the amount withheld.On each operation (Agreement 142/18, clause twentieth).
DIFALPayment to the destination, with a portal and central calculation planned.LC 87, art. 24-A, and Agreement 236/21. Payment slip and deadline by state: not checked.
FCIImport content of the product, with the number reported in the NF-e.ICMS Agreement 38/13 and its amendments.
EFD-Contributions, ECD and ECFPIS and Cofins and the accounting and tax books.Not checked: rules not read in this round.
Block K

Block K record by record: what production must feed

Each record describes a fact of the factory. Where the production order, the consumption or the third party does not reach the tax team, the record leaves empty or different from the stock.

K010

Layout adopted in the block. 0, simplified; 1, full; 2, limited to stock balances. From 01/01/2023 the taxpayer may file the simplified one, under the conditions of Ajuste SINIEF 02/09 (which conditions: not checked). In the simplified layout, K210 and K215 are not required, and K235 and K255 are not mandatory.

K100 and K200

Period of calculation and final booked stock. K200 goes by item type and, when it applies, by participant: 00 resale, 01 raw material, 02 packaging, 03 in process, 04 finished, 05 by-product, 06 intermediate and 10 other inputs. Type 07, use and consumption, is not in the K200 list.

K230 and K235

Production of in-process and finished product, except joint production, and the inputs consumed in each. In the full layout, with the order dates inside the K100 period, K235 is mandatory. Since 01/01/2023 the key of K235 became DT_SAÍDA and COD_ITEM, with record 0210 discontinued.

K250 and K255

Product made by a third party on order, and the inputs sent and consumed in it. K255 is mandatory only if K250 exists. The key of K255 is the consumption date and the input code.

K260 and K265; K210, K215 and K220

Reprocessing or repair, disassembly and other internal movements between goods. K260 applies to reprocessing in the same establishment, where the item keeps its code. Reprocessing done in another establishment has no record of its own in the block. K270, K275 and K280 correct entries from earlier periods.

K290 to K292; K300 to K302

Joint production, in the factory and at a third party. Joint production is the making of more than one product from the consumption of inputs in a common production flow. K290 holds the order, K291 the items produced and K292 the inputs. Records K300, K301 and K302 do the same when production happens at a third party.

Official source, read on 22/10/2026

EFD ICMS/IPI Practical Guide, records K010, K200, K230, K235 and K255, and Ajuste SINIEF 02/09, clause third, §7 and §14. The Guide itself shows record 0210 as valid until 31/12/2021 and, in the note on K235, speaks of discontinuation since 01/01/2023. The mismatch is in the text of the Guide, and the current version for each period is left to check on the SPED portal.

DFSpro judgment

The choice between the simplified and the full layout is the client's decision, with support from what the state accepts. What belongs to the SAP setup is making sure that every production order, every shipment to a third party and every reprocessing leaves a trace that supports the record.

Reform

The transition to IBS, CBS and IS, on dates read in the law

2026, conditional exemption

The law sets IBS at 0.1% and CBS at 0.9%, but whoever meets the ancillary obligations is free from paying (art. 348, § 1), while PIS and Cofins stay in full (§ 2). Whoever pays offsets it against those contributions; if there is no debit, the amount reduces another federal tax or is refunded within up to 60 days (art. 348, II). A company in the Simples regime is left out (item III, c).

2027 and 2028, CBS in place of PIS and Cofins

CBS and the Selective Tax come in, and PIS and Cofins go out, as long as CBS has been created. IPI rates go to zero, with an exception for the Manaus Free Trade Zone. In the IBS share, the state keeps 0.05% and the city 0.05%.

2029 to 2032, ICMS falling

ICMS and ISS rates are 9/10 in 2029, 8/10 in 2030, 7/10 in 2031 and 6/10 in 2032 of the rate set in the law, and the tax benefits fall in the same proportion (ADCT, art. 128).

2033, end of ICMS

With the end of ICMS and ISS, the ICMS credit balances that exist at the end of 2032 will be used as set by a complementary law (ADCT, arts. 129 and 134).

Official source, read on 19/10/2026

The Selective Tax applies to the production, extraction, sale or import of goods and services that harm health or the environment, with rates set by ordinary law (LC 214, arts. 409 and 422). The EFD ICMS/IPI Practical Guide says that the EFD is not meant for calculating CBS, IBS and IS.

DFSpro judgment

In industry, the sensitive point is the two credit regimes living together between 2027 and 2032 and the ICMS credit balance that reaches 2033. A company with plants in more than one state needs to know, plant by plant, how much credit it carries and from what origin.

Industry in the reform

Capital goods, stock, Free Trade Zone and incentives: what the law already says

Points of LC 214 and nearby rules that industry feels before 2027. Where the rule depends on an act not yet read, the text says it was not checked.

TopicWhat the text read says
Capital goods, full creditIn the new regime, buying a capital good gives full and immediate IBS and CBS credit (LC 214, art. 108). A joint act of the Union and the Management Committee may set a suspension of payment, turned into a zero rate after the good enters fixed assets, with payment plus penalty and interest if the good is not booked as an asset (art. 109). The list of goods and the joint act: not checked.
Stock on January 1, 2027Art. 381 allows a presumed CBS credit on the stock of physical goods in three cases: a company in the cumulative PIS and Cofins regime on 31/12/2026, stock bought under ST or single-stage taxation, and the part under partial credit restriction. It only applies to new goods, outside fixed assets and real estate. A good bought in Brazil gives a credit of 9.25% of the stock value; for an imported good, it is the amount of the PIS/Pasep-Import and Cofins-Import actually paid (art. 381, § 3, II). It is taken until June 2027, used in 12 monthly installments and can only offset CBS.
Stock, what is still missingArt. 381 requires an act of the Federal Executive Branch to set the stock check, and it may require an inventory and valuation. That act was not read: not checked. Art. 383 ends the right to use the credit five years after it is taken. Who takes it, and how, is the client's decision.
Manaus Free Trade Zone, current regimeDecree-Law 288, art. 9, exempts from IPI the goods produced in the Manaus Free Trade Zone, for internal consumption or sale anywhere in the national territory. Paragraph 1 makes the exemption, when the product goes to other regions, depend on the requirements of art. 7 of the same decree-law, which were not read.
Manaus Free Trade Zone, in LC 214The term of the benefits is the one in ADCT art. 92-A. It adds 50 years to the term in art. 92, which already adds ten years to the one in art. 40, set at 25 years from the promulgation. The final date is our calculation, not the text of the law. Art. 442 requires registration with Suframa and, for the incentivized industry, an approved technical-economic project under the basic production process (wording of LC 227).
Manaus Free Trade Zone, creditsArt. 441 leaves out of the favored regime weapons and ammunition, tobacco, alcoholic drinks, passenger cars, oil and fuels (with an exception for refining in Manaus) and perfumery and cosmetics, with some exceptions. Art. 443 suspends IBS and CBS on imports by an incentivized industry, turned into an exemption when the good is consumed or built into the production process of the importer in the Manaus Free Trade Zone, or after full depreciation or 48 months in fixed assets, whichever comes first (§ 2). Art. 450 gives a presumed IBS credit of 55% to 100% of the amount due, by type of good, and a CBS credit of 6% or 2% of the operation value. Effective dates of each part: not checked.
Selective Tax in industryArt. 412 includes among the taxable events the entry of the good into fixed assets by the industrial company and its consumption of the good. Art. 424 makes the industrial company the taxpayer on the first supply, on entry into assets, on a transfer with no payment and on consumption. For a company that makes a good under the Selective Tax and uses it in its own plant, the taxable event can arise inside the factory.
IT Law and the end of articles of Law 11.196Law 8.248, art. 4, gives financial credit to those who invest in research, development and innovation in information and communication technology goods. The current main text, in the wording of Law 14.968/2024, has no date; the term until 31/12/2029 comes from art. 11 of that same Law 14.968. Paragraph 1-C, which tied the benefit to the basic production process, is shown as repealed by Law 13.969/2019. Arts. 55 to 59 of Law 11.196, tied to the credit of the chemical industry, and the date of the repeal by LC 214 are on the page on chemicals and petrochemicals.
Official source, read on 22/10/2026

LC 214/2025, arts. 108, 109, 381, 383, 412, 424, 439 to 445, 450 and 542; Constitution, ADCT, arts. 40, 92 and 92-A, and Constitutional Amendment 83/2014; Decree-Law 288/1967, art. 9; Laws 8.248/1991, 13.969/2019, 14.968/2024 (art. 11) and 11.196/2005. Compiled text on the Planalto site.

DFSpro judgment

Stock and capital goods are the two points where the material master decides the credit. If the classification between input, capital good and use and consumption is loose, the transition inherits the error. The thesis for taking the credit is the client's.

Sector situations

Where the tax process becomes a project

These are typical situations of the sector, described as a pattern and not as a client case. Here DFSpro steps in on the design, the setup and the proof of how SAP behaves, and the tax decision stays with the company.

15

situations where the process becomes a project

Fixed assets, stock, credits, withholdings and migration: where volume and rules make the work heavy, and where a well-proven design takes the process out of the spreadsheet.

01

Production line: depreciation by method, by area and by component

What weighsA machine can depreciate by time or by output, in three sets of books.

What DFSpro changesAsset record by line, with the statutory, tax and management areas kept apart and reconciled.

See the situation, the basis and the proof

The situationThe factory has presses, furnaces and assembly lines with different useful lives and rates of use. Accounting may depreciate by units produced, the tax side uses an allowed rate, and management wants another view.

Legal basisRIR arts. 317 to 321; CPC 27

The proof deliveredRecord by line reconciled with the ledger in the three views, and a report of the accounting and tax difference.

02

Work shifts and the accelerated depreciation coefficient

What weighsThe same machine on three shifts depreciates faster.

What DFSpro changesCoefficient tied to the real shift, by equipment and by month.

See the situation, the basis and the proof

The situationThe factory goes from one to three shifts as demand changes. The machine works more hours, and the wear changes.

Legal basisRIR arts. 323 and 324

The proof deliveredReport of the coefficient by equipment and month, reconciled with the charge.

03

Idle plant, loss of value and revaluation of an asset held for sale

What weighsAn asset that no longer gives a return must be tested.

What DFSpro changesTraced impairment test, with the loss posted by record.

See the situation, the basis and the proof

The situationThe company closes a line or a plant and plans to sell the assets. The book value may be higher than what can be recovered.

Legal basisCPC 01; ICPC 10

The proof deliveredReport by record with the value before, the loss and the value after.

04

Sale and write-off of a machine: result, CIAP and tax control

What weighsSelling a machine touches three records at the same time.

What DFSpro changesWrite-off script with result, credit and control in one flow.

See the situation, the basis and the proof

The situationThe factory sells a used machine or writes it off as obsolete. The gain or loss goes to the result, the CIAP balance is handled and the tax control records the adjustment.

Legal basisLC 87 art. 20 § 5; Ajuste SINIEF 02/09

The proof deliveredScenarios tested with invoice, ledger, CIAP and tax control reconciled.

05

Planned shutdown and maintenance: expense or longer useful life

What weighsA major shutdown can renew the asset or only maintain it.

What DFSpro changesMaintenance order with a clear criterion and the right destination in assets.

See the situation, the basis and the proof

The situationIndustry runs major shutdowns, with part replacement and inspection. Part of it maintains the asset; part extends its useful life.

Legal basisRIR art. 313; CPC 27

The proof deliveredShutdown scenarios with expense and asset reconciled.

06

Machine that moves to another plant: asset transfer and CIAP

What weighsMoving a machine to another plant changes the CNPJ, the record and the credit.

What DFSpro changesAsset transfer script with the invoice and the CIAP following along.

See the situation, the basis and the proof

The situationThe company moves equipment between plants in different states. The record, the invoice and the balance of credit installments must follow the asset.

Legal basisLC 87 art. 20 § 5; Ajuste SINIEF 02/09

The proof deliveredScenario tested with invoice, record in both plants and CIAP.

07

Stock cost without recoverable tax, by plant

What weighsThe accounting cost and the tax cost of stock are not the same.

What DFSpro changesCost with recoverable taxes separated and checked.

See the situation, the basis and the proof

The situationThe finished product is valued at average cost. The accounting cost leaves out recoverable tax; the tax side follows another rule.

Legal basisCPC 16 (R1)

The proof deliveredPurchase scenarios with cost, credit and ledger reconciled.

08

Unit of measure, conversions and bill of materials in Block K

What weighsBuys in tons, produces in pieces, sells in boxes.

What DFSpro changesConversions by material, checked against the bill of materials.

See the situation, the basis and the proof

The situationThe factory buys in bulk, consumes in kilos and sells in boxes. Each unit has a conversion factor.

Legal basisEFD Practical Guide, Block K

The proof deliveredReport of items with an inconsistent factor before and after, and K200 reconciled.

09

Scrap, waste and by-product: from production to sale

What weighsWaste is recorded in production and sold later.

What DFSpro changesWaste entry tied to the sale and to Block K.

See the situation, the basis and the proof

The situationProduction creates trimmings and scrap. The volume is recorded, stored and sold to recyclers.

Legal basisLaw 11.196/2005 arts. 47 and 48

The proof deliveredScenario tested with entry, stock and invoice.

10

Drawback: import an input, produce and export with the balance up to date

What weighsEach import must match an export.

What DFSpro changesLink between import, production and export traced by concession act.

See the situation, the basis and the proof

The situationThe industrial company imports an input under suspension and exports the product. The balance of each concession act must close on time.

Legal basisLaw 11.945/2009 art. 12

The proof deliveredReport of the balance by concession act and item, with the documents.

11

Accumulated ICMS credit from exports: calculate, use and transfer

What weighsWhoever exports builds up credit with no taxed output to offset it.

What DFSpro changesCredit balance calculated by establishment and by period.

See the situation, the basis and the proof

The situationThe industrial company exports much of its output and builds up an ICMS credit balance. That balance can be used or transferred, under the terms of the law.

Legal basisLC 87 art. 25 § 1

The proof deliveredCredit balance by establishment and period, reconciled with the EFD.

12

Migration of fixed assets from ECC to S/4HANA

What weighsRecord balances, accumulated depreciation and CIAP must migrate intact.

What DFSpro changesLoad checked record by record against the ledger and the CIAP.

See the situation, the basis and the proof

The situationThe factory migrates to S/4HANA with thousands of records, many with accumulated depreciation in different areas and a CIAP balance still running.

Legal basisLC 87 art. 20 § 5; RIR arts. 317 to 321

The proof deliveredRecord-by-record check between ECC and S/4HANA, with the difference at zero or explained.

13

Scrap in industry after STF Theme 304

What weighsThe sale and purchase of scrap changed rules by a court decision.

What DFSpro changesTax parameter for scrap with a history of validity and proof.

See the situation, the basis and the proof

The situationThe factory sells trimmings and scrap and buys recyclable material. The rule on suspension and on the ban on credit was the subject of an STF decision.

Legal basisSTF, Theme 304; Law 11.196/2005 arts. 47 and 48

The proof deliveredScenarios of scrap sale and purchase with the tax expected and obtained by period.

14

Maintenance part: does it extend the useful life or only maintain the asset

What weighsWhoever sees the part as an asset or as consumption changes the credit.

What DFSpro changesClassification criterion in the master data and in the maintenance order, with proof.

See the situation, the basis and the proof

The situationThe factory replaces machine parts. If the part extends the useful life, the tax authority may see an asset; if it only keeps the performance standard, it is consumption.

Legal basisRICMS/MG (art. 66); LC 87 art. 20

The proof deliveredOrder scenarios with the expected and obtained destination, CIAP and credit.

15

ICMS subsidy and the tax credit of Law 14.789

What weighsThe state benefit changes treatment in income tax.

What DFSpro changesTrace of the subsidy from the document to the calculation and to the application for qualification.

See the situation, the basis and the proof

The situationIndustry uses state ICMS incentives. For income tax, the STJ set a thesis in a repetitive case and Law 14.789/2023 created a subsidy tax credit, which requires qualification with the Federal Revenue Service.

Legal basisSTJ, Theme 1,182; Law 14.789/2023; IN RFB 2.214/2024

The proof deliveredReport by benefit, with documents, revenue and reconciliation with the ECF.

Which of these situations is yours? The Tax Diagnostic shows how each one stands today in your SAP and what needs to be designed and proven first.

Learn about the Tax Diagnostic
What DFSpro solves

Time and proof gained in industry

Six points where a multi-plant industry loses time in SAP, and what DFSpro does on each. The tax thesis of each case stays with the client.

Free Trade Zone

Manaus benefit with qualification and date

In LC 214, the benefits of the Manaus Free Trade Zone last until the date in ADCT art. 92-A and require qualification of the incentivized industry. The benefit is usually applied through the master data, and the qualification is left out of the calculation. DFSpro designs the rule by qualification and product; what to apply is the client's decision.

Stock of 01/01/2027

Inventory by item and by case

Art. 381 of LC 214 provides a presumed CBS credit on the stock of January 1, 2027 in three groups of cases. Industry holds more than one type of item in stock and must classify each one. DFSpro builds the inventory by case; whether to take the credit or not is the client's decision.

Capital goods

Credit today and credit in 2027

Today the ICMS on assets is used in 48 installments through the CIAP (LC 87, art. 20, § 5). With the reform, buying a capital good gives full and immediate IBS and CBS credit (art. 108 of LC 214). The classification between asset and use and consumption sets both credits. DFSpro takes the client's criterion to the master data and proves both scenarios.

Block K

Close by type of industry

Assembly, process and capital goods industries produce different records, such as K230, K235 and joint production. DFSpro maps the production order, the bill of materials and the entry through to the record, and proves that Block K closes with the shop floor.

Between plants

Transfer with no credit balance left without an owner

After LC 204/2023, the wording of art. 12, I, of LC 87 changed. An industry with several plants may carry the old rule in its master data. DFSpro redesigns the transfer scenario and proves the credit in SAP.

Input with ST

ST where it did not need to exist

Clause 9 of ICMS Agreement 142/18 excludes the industrial input from ST under specific conditions. The master data does not always know that the establishment is industrial. DFSpro takes this condition to the master data and tests the purchase of inputs by state.

Where the client starts

Each point above ends in a choice that only the client makes. We deliver the setup and the proof that SAP behaves as the company chose.

Learn about the SAP Tax Diagnostic
How DFSpro steps in

Diagnostic, AMS Fiscal and GUEPARDO Tax in the plants

Tax diagnostic

It maps the ICMS, ST, DIFAL, IPI and credit setup in use at each plant, compares it with the rule read and ranks by risk: critical, high, medium or monitor. It delivers a list with hierarchy and proof, not generic advice.

Project and AMS Fiscal

It builds in SAP the setup of the rule the client chose for each route between plants and tests the result. In AMS Fiscal, it follows the changes in agreements, adjustments and annexes through the year and checks the effect at each plant.

GUEPARDO Tax

In GUEPARDO Tax, from NTT DATA, DFSpro is an Authorized Channel: it supplies the license, implements and looks after governance. In the plants, the treatment the client defined for each route is proven in this environment.

To go deeper

SAP Tax DiagnosticMapping, analysis and risk priority in the multi-plant setup.ECC to S/4HANA migrationCheck ST, DIFAL and credit again when plants are merged or upgraded.CBS and IBS system adaptationICMS on the routes between plants living with IBS and CBS in the transition.GUEPARDO TaxLicense, implementation and governance of the NTT DATA product, by an Authorized Channel.MethodologyHow DFSpro maps, proves and ranks.PortfolioThe services and the environments where we work.

Blog articles on industry and manufacturing

Limit of our role

The tax decision is the client's: for example, whether to treat the transfer as a taxed operation (LC 87, art. 12 §5), how to handle the credit balance or what thesis to adopt in each state. In the plants, DFSpro builds the setup in SAP and proves, with a test invoice, that it reproduces the client's choice.

Sources

Official sources read, last checked on 22/10/2026

Rules from the first round, opened on 19/10/2026. Ajuste SINIEF 02/09 (Block K), LC 214 (arts. 108, 109, 381, 412, 424, 439 to 445, 450 and 542), the Constitution, EC 83, Decree-Law 288 and Laws 8.248, 13.969, 14.968 and 11.196, opened on 22/10/2026. If your operation depends on a state rule or an annex not listed here, the item stays open until it is read.

Constitution and laws (Planalto)

CONFAZ

SPED

Supreme Federal Court

Frequently asked questions

Questions from the tax director of an industrial company on ICMS, ST and credit

01Does the transfer between my plants pay ICMS?+

Since 01/01/2024 it is not a taxable event: LC 204 barred ICMS and kept the earlier credit, and the STF modulated ADC 49 to the 2024 tax year, except for cases pending until 29/04/2021. The law also allows treating the transfer as a taxed operation, by option. The choice is the client's.

02Can I transfer credit from one plant to another?+

LC 204 provides that the destination secures the credit by transfer, limited to the interstate rate on the transferred value, and that the origin secures the positive difference. The STF added that, if the states do not regulate the transfer of credits in time, the right is recognized. How each state handles this: not checked.

03Does ST apply to the input that one plant sends to another?+

Unless the rule says otherwise, Agreement 142/18 rules out ST on the shipment of raw material, intermediate product or packaging to an industrial company that does not sell the same good, and on a transfer between establishments of the sender, except to a retailer. The destination state may set it differently.

04How do I know if a product is under ST?+

By the list in Annexes II to XXVI of the agreement, which gives NCM, CEST and description. If the item description does not repeat the NCM one, it only applies to the good described, and a change in the NCM code neither adds nor removes the item. The list of items itself was not read for this page.

05Is there DIFAL on a transfer between plants?+

Not as a transfer rule. DIFAL covers the final consumer who is not a taxpayer in another state, due from the sender, and the entry of a good for use, consumption or fixed assets by a taxpayer, due from the recipient (EC 87 and LC 190). Each case depends on the destination state.

06Is Block K mandatory for my factory?+

It depends on revenue and activity. For an industrial establishment of a company with revenue of BRL 300 million or more, Ajuste SINIEF 02/09 sets dates by CNAE division, from 2019 to 2025 for full bookkeeping. For revenue of BRL 78 million or more and for the other industrial companies, the text provides stock balances since 2018 and 2019, with a schedule still to be set (not checked). For a company in the Simples Nacional regime, the Practical Guide records the exemption.

07Why is K235 sometimes not mandatory?+

Because it depends on the layout flag in K010 and on the dates of the production order. In the full layout, with the order dates inside the K100 period, K235 is mandatory. In the simplified one, the company is relieved of that record, according to the notes of the Practical Guide.

08Does use and consumption go into the Block K stock?+

K200 lists item types 00 to 06 and 10 (resale, raw material, packaging, in process, finished, by-product, intermediate and other inputs). Type 07, use and consumption, is not in that list. Whoever has a K200 with a use and consumption item should review the item type in the material master.

09Does my 2026 stock turn into CBS credit?+

Art. 381 of LC 214 provides a presumed CBS credit on the stock of 01/01/2027 in three cases: cumulative PIS and Cofins regime in 2026, goods that came in under ST or single-stage taxation, and the part with partial credit restriction. The rate is 9.25% for a good bought in Brazil, taken until June 2027. The act that sets the stock check was not read. Fitting into the rule is the client's analysis.

10Does a company that produces in the Manaus Free Trade Zone lose the benefit with the reform?+

LC 214 keeps its own regime for the incentivized industry, with registration with Suframa, suspension on imports and presumed IBS and CBS credits (arts. 439 to 450), while the terms of ADCT art. 92-A hold. The effective date of each part of the text was not checked.

11Does a new machine give all its credit at once in the reform?+

Under LC 214, art. 108, the IBS and CBS credit on buying capital goods is full and immediate. The ICMS on fixed assets is still taken in 48 months, through the CIAP (LC 87, art. 20, §5). During the transition the two regimes live together, and a joint act may provide for a suspension of payment (art. 109).

12How does the CIAP take the credit on the asset?+

LC 87 requires the credit to be taken in 48 monthly installments, multiplied by the share of taxed outputs, including exports, in the total outputs of the period. In the EFD, Block G, record G110, carries the balance, the installments and the participation index.

13When is the interstate rate 4%?+

When the good is imported and was not processed, or when, even if processed, the import content passes 40% (Agreement 38/13). Left out are the good with no national equivalent on the Camex list, the one made under the basic production process and imported natural gas.

14Does IPI stop existing with the reform?+

EC 132 cuts IPI rates to zero from 2027, except for products with incentivized industrialization in the Manaus Free Trade Zone. Until then the RIPI applies: taxable event on the output from the industrial establishment and credit on raw material, intermediate product and packaging.

15Will the EFD ICMS/IPI calculate IBS and CBS?+

No. The EFD ICMS/IPI Practical Guide says that the EFD is not meant for calculating CBS, IBS and IS. The new taxes enter the total value of the document (field VL_DOC of C100, except in 2026) and stay out of the operation value in the analytic records.

16When does a tax diagnostic make sense?+

When there are two or more plants in different states, movement of inputs or products between them, ST in at least one operation or a credit mismatch already seen. The diagnostic compares the setup with the rule and ranks by risk.

17What should the tax team of an industrial company gather before the first meeting?+

The plants by state, the three or four transfer routes with the most volume, the latest credit or ST mismatches and the SAP version. With this material, the first meeting already settles where to start.

Next steps

Bring the plants, the states and the transfer routes that worry you most

Tell us in which states you have a factory, what travels between them and which route has already shown a mismatch. From there the first design is built.

Bring the plants and the routes to the conversationSee your readiness in 2 minutes

To read before the meeting: the page on tax diagnostic in SAP and the one on system adaptation to CBS and IBS.