
Associates Blog

7 Questions About Internment (PIN-e) in Domestic Purchases
25 de dez de 2024
2 min read
By Yonna Benshalom G. Oliveira, Tax Partner.
Under the supervision of Coordinating Partner Ninfe Mota Dantas.

To ensure ICMS and/or IPI exemptions on shipments of goods/materials produced or nationalized in Brazil to the Manaus Free Trade Zone (ZFM), the Western Amazon, and Free Trade Areas (ALCs), it is necessary to carry out the “internment” of these items. The process begins with the issuance of the electronic National Goods Entry Protocol (PIN-e).
Below are the seven main questions about this topic:
1. What is the legal basis?
• ICMS Agreement No. 134/19
• SUFRAMA Ordinance No. 834/19
• Law No. 13,451/17
• Decree No. 7,212/10 – RIPI (Articles 81 to 120).
2. To which regions does internment apply?
• Manaus Free Trade Zone (ZFM): Manaus (AM), Rio Preto da Eva (AM), and Presidente Figueiredo (AM).
• Western Amazon: Amazonas, Rondônia, Acre, and Roraima.
• Free Trade Areas (ALCs): Tabatinga (AM), Guajará-Mirim (RO), Macapá and Santana (AP), Cruzeiro do Sul and Brasiléia, extending to Epitaciolândia (AC), as well as Boa Vista and Bonfim (RR).
3. Who is responsible for the internment process?
• The supplier (sender) must issue the PIN-e (one for each tax-incentivized invoice).
• The buyer (recipient) must confirm or refuse receipt.
• Both parties must be registered in CADSUF (SUFRAMA Registration System) and are responsible for monitoring the entire internment process.
4. When should the PIN-e be issued?
Whenever a tax-incentivized invoice (ICMS/IPI) is issued for goods/materials shipped to the regions mentioned (see question 2) for industrialization or resale purposes.
5. How should the internment process be monitored?
Through the National Goods Entry System (SIMNAC):
• National Goods Entry System - SIMNAC
6. Are there deadlines to be observed?
• Completion of the internment process: Within 120 days from the invoice issuance date.
• Exception - “Delayed Inspection”: 120 days from the invoice issuance date.
• External Inspection: 3 business days
• Internal Inspection: 1 business day
• Document Inspection: 5 business days
7. What are the main risks of failing to complete the internment?
• Payment of ICMS by the supplier (at origin) and the reversal of the ICMS Presumed Credit by the buyer (at destination), requiring payment of the respective amount.
• Non-compliance may result in audits and potential issuance of an Infraction Notice.