What you need to know about Anatel's Convenio 115

Anatel's famous convention 115, which dates back to December 2003, establishes a series of requirements in relation to the bookkeeping, issuing and keeping of tax documents corresponding to services provided by taxpayers in the telecommunications and electricity sectors.

Those who deal with these procedures often have a number of doubts. After all, these are the procedures to be carried out in order to generate NF's in compliance with the established regulations. To help you, we've put together this post with everything you need to know. Check it out!

Issuing and bookkeeping tax documents

First of all, we need to understand which tax documents are regulated by Convention 115. According to the first clause of the norm, they are:

I - Invoice/Electricity Bill, model 6;

II - Communication Service Invoice, model 21;

III - Telecommunications Service Invoice, model 22;

IV - any other tax document relating to the provision of communication services or the supply of electricity.

Knowing which tax documents are of interest, we should point out that:

• Whether or not it is mandatory to obtain an Authorization to Print Tax Documents (AIDF) is up to each state in the federation;
• All the information on the first copy of the tax document must be saved on non-rewritable electronic media (CD or DVD, for example) by the fifth working day of the month following the tax period.

Recording information according to agreement 115

Agreement 115 also clearly specifies how the data is to be recorded in barcodes, which must contain:

a) record type;

b) tax document number;

c) CNPJ registration number of the issuing and receiving establishments;

d) Federation unit of the issuing and receiving establishments;

e) date of the transaction or service;

f) amounts of the operation or provision and ICMS;

g) indicator of a transaction subject to tax substitution.

Information must be encrypted using the MD5 algorithm (Message Digest 5). Further information on the operation of digital bookkeeping can be found at Practical Guide to Digital Bookkeeping - EFD ICMS/IPI

Information archiving

Agreement 115 also lays down provisions for archiving information. The saving of data on optical media, for example, must comply with the following division of files:

I - "Tax Document Master" - with basic information on the tax document;

II - "Tax Document Item" - detailing the goods or services provided;

III - "Tax Document Recipient's Registration Data" - with the tax document recipient's registration information;

The agreement also includes the following provisions on data saving:

1º The files referred to in the heading must be organized and grouped according to the templates and definitions in the Guidance Manual in the Single Annex to ICMS Agreement 115 of December 12, 2003.

2º The files will be generated with the same periodicity as the taxpayer's ICMS assessment, and must contain all the tax documents for the assessment period.

3º A set of the files listed in the caput of this article will be generated, distinct for each model and series of tax document issued in a single copy.

4º The set of files will be divided into volumes whenever the quantity of tax documents reaches 1 (one) million tax documents.

5 The media used must contain the files listed in the heading of this article relating to each volume of tax documents, as well as the validator and the consultation program.

6º The integrity of the files will be guaranteed by the linking of digital coding keys, calculated on the basis of all the information contained in each file, which will appear in the control and identification file, as well as on the volume delivery receipt.

After following all the explanations in this post about the 115 agreement, we're sure you're ready to solve the problems in your company that concern the issuing, bookkeeping and filing of invoices.

Pay special attention to the provisions contained in the guidance manuals provided, as they are the most reliable source of information for dealing with your obligations.

What did you think of today's post? Any questions about covenant 115? Leave a comment!

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