Law No. 12973 of May 13th, 2014, establishes that the disclosure of adjustments resulting from adoption of the new accounting methods and criteria should be made by subaccount linked to assets or liabilities subject to adjustments. Similar treatment was given to any differences in the duration of the Transition Tax Regime (RTT).

Normative Instruction RFB No. 1515, of November 24th, 2014, regulated the law, providing the possibility in the case of an account that refers to a group of assets or liabilities, according to the nature of them, a subaccount may refer to the same group of assets or liabilities, provided that the auxiliary accounting book demonstrates the individual breakdown by asset or liability.

The requirement for transmission to the Sped of the auxiliary accounting book, provided in Normative Instruction No. 1515, 2014, proved to be highly complex for taxpayers, given the amount of adjustments and the amount of assets / liabilities existing in the entities, which could impact in the information technology environment of the companies.

Thus, the IRS published the Normative Instruction RFB 1638, which eliminated the transmission requirement of auxiliary accounting book to Sped, aimed at simplification of tax obligations and meeting the request of the productive sector. It is important to note that the measure does not exempt the taxpayer to prepare and maintain the auxiliary accounting book for the limitations period, which is done through the repeal of paragraph 5 of art. 33 and Paragraph 7 of art. 169, both of Normative Instruction RFB No. 1515, of November 24th, 2014.