Tax planning for the transition
Choosing a tax regime has always been a one-year calculation: you make it in January and it holds until December. The reform makes that calculation longer. Between 2027 and 2033 the rules change almost every year, and the answer that holds today may stop holding in 2029. Transition planning projects your company's burden under each regime, year by year, to show the year in which the choice changes and what to do before then.
Who it is for
For companies under any regime, whether Simples Nacional, Presumed Profit (Lucro Presumido) or Actual Profit (Lucro Real), that want to decide based on numbers projected through 2033, and not only on next year.
A projection is usually worthwhile if your company:
- is under Simples Nacional and sells to companies under Presumed Profit or Actual Profit;
- is under Presumed Profit and its real profit margin differs from the margin the law presumes;
- is under Actual Profit and wants to evaluate Presumed Profit now that the cumulative PIS and Cofins are ending;
- is growing and approaching a threshold: the Simples sublimit, the Simples ceiling of R$ 4.8 million or the R$ 78 million limit for Presumed Profit;
- is changing its customer profile, for example from final consumers to businesses;
- wants a clear calendar of the decisions ahead.
This work runs alongside the company's accountant, who remains responsible for day-to-day tax calculations.
What changes and when
The reform gradually replaces the taxes on consumption: PIS and Cofins become the CBS, and ICMS and ISS become the IBS. The switch runs through 2033, and each stage changes the calculation for each regime in a different way.
| When | What happens |
|---|---|
| 2026 | Test year. Current taxes continue. The CBS at 0.9% and the IBS at 0.1% are offset against PIS and Cofins, and companies that comply with ancillary filing obligations are excused from paying. Simples companies are outside the test rates. |
| 2027 and 2028 | PIS and Cofins end and the CBS is charged in full, at the reference rate minus 0.1 percentage point. The IBS is charged at 0.1% in total. |
| 2029 to 2032 | ICMS and ISS fall by 10 percentage points a year, to 60% of current rates in 2032, and the IBS rises in the same proportion. |
| 2033 | ICMS and ISS are abolished. IBS and CBS apply in full. |
The reference rates for the CBS and the IBS are set by the Senate. The CBS rate for 2027 is not yet defined: the deadline is December 15, 2026. The IBS rates, from 2029 to 2033, will be set later.
What changes in the choice of regime
The consumption tax reform does not change how companies calculate income tax (IRPJ) and the social contribution on profit (CSLL). Simples, Presumed Profit and Actual Profit continue to exist. What changes is what these regimes do with the consumption taxes.
Through 2026, the profit regime chosen generally determined the PIS and Cofins regime: cumulative and without credit under Presumed Profit; non-cumulative and with credit under Actual Profit. From 2027 that difference ends. Presumed and Actual Profit calculate the CBS and the IBS the same way, under the regular regime, with a right to credit. The comparison between them then depends mainly on IRPJ and CSLL.
The four paths we compare:
- Unified Simples NacionalIBS and CBS stay inside the DAS (the single payment slip), at the annex rate. There are fewer obligations, but the customer who buys from you can use only a small credit. It tends to suit those who sell to final consumers.
- Hybrid Simples NacionalThe company stays in Simples for IRPJ, CSLL and the employer social security contribution, and calculates IBS and CBS under the regular regime, outside the DAS. It delivers full credit to the customer and starts taking credit on its own purchases, with more document control.
- Presumed Profit (Lucro Presumido)IRPJ and CSLL are calculated on a presumed percentage of revenue, for companies with revenue of up to R$ 78 million in the prior year. Complementary Law 224/2025 adds 10% to the presumption percentages on the portion of gross revenue above R$ 5 million in the year. IBS and CBS under the regular regime.
- Actual Profit (Lucro Real)IRPJ and CSLL are calculated on actual profit, with the possibility of offsetting losses. It is mandatory above R$ 78 million in prior-year revenue. IBS and CBS under the regular regime, as under Presumed Profit.
When the real margin is below the presumed margin, Actual Profit tends to cost less in IRPJ and CSLL. When it is above, Presumed Profit tends to cost less. The full calculation also includes the cost of a more complex process under Actual Profit.
Why the calculation changes year by year
In 2027 and 2028, the difference between the paths lies almost entirely in the CBS, because the IBS is charged at 0.1% in total. From 2029, the IBS grows, ICMS and ISS shrink and the weight of the IBS credit enters the calculation. Anyone who decides by looking only at 2027 may get the first year right and the following ones wrong.
The outcome of each path depends on variables that differ from one company to another: who the company sells to, how much it buys with a right to credit, what its real margin is, how heavy its payroll is (which does not generate IBS and CBS credit), which revenue bracket it is in and whether it will cross any threshold over the years.
There is also uncertainty in the rules themselves. The 2027 CBS rate will be set by the Senate by December 15, 2026, and the IBS rates from 2029 onward will come later. That is why the projection works with stated assumptions and is redone when they change.
The decision dates
| When | What happens |
|---|---|
| September 1 to October 30, 2026 | Simples companies: election of the regular IBS and CBS regime (outside the DAS), effective from January 1, 2027. Those who do not elect stay in the DAS. |
| November 3 to December 20, 2026 | Cancellation of that election. |
| By December 15, 2026 | The Senate sets the CBS reference rate for 2027. |
| First installment of 2027 | Presumed Profit: the election is expressed by paying the first or only installment of the tax for the first assessment period and holds for the whole year. |
For IRPJ and CSLL, the choice of regime holds for the whole year and cannot be changed mid-year. The deadline to join Simples in 2027 was October 15, 2026. The decision on IBS and CBS inside or outside the DAS is covered in our Simples vs. VAT service.
Four situations, four different answers
The examples below are illustrative: they show how the answer changes with the profile, not real client cases.
Those who sell to businesses
Buyers under the regular regime want to use full IBS and CBS credit. A unified Simples supplier delivers a small credit, which can weigh in the negotiation.
Illustrative example: A Simples packaging manufacturer sells nearly everything to retail chains under Actual Profit. The projection compares staying in the DAS with the hybrid route, year by year, and shows whether the credit delivered to the customer justifies the additional cost and control.
Those who sell to final consumers
The final consumer cannot use credit. In this case, the simplicity of unified Simples usually remains competitive.
Illustrative example: A clinic that treats private patients tends to remain in the unified route. The projection confirms this and indicates the point at which a change of profile or revenue would flip the calculation.
Those whose margin differs from the presumption
Under Presumed Profit, IRPJ and CSLL apply to a fixed percentage of revenue. Under Actual Profit, they apply to actual profit.
Illustrative example: A services company has a real margin of 12%, well below the margin the law presumes under Presumed Profit. If the gap persists, Actual Profit tends to cost less in IRPJ and CSLL, and the projection includes the cost of a more complex process.
Those who grow and move into a new bracket
More revenue leads to new thresholds: the Simples sublimit, the Simples ceiling of R$ 4.8 million and the R$ 78 million limit for Presumed Profit.
Illustrative example: A distributor approaching one of these thresholds needs to know in advance what changes in its burden and in its customers' credit when the threshold is crossed.
What we deliver
You receive a projection for each regime, with the assumptions in plain view, and a recommendation to decide with.
- Comparison of unified Simples Nacional, hybrid Simples Nacional, Presumed Profit and Actual ProfitThe four paths side by side, calculated with your company's data, not market averages.
- Year-by-year projection, 2027 to 2033, based on Complementary Law 214/2025The burden of each path in each year of the transition, to see the year in which their ranking flips.
- A scenario of staying in the current regime and a scenario of following the best path each yearThe gap between standing still and following the transition, with the year in which each switch starts to make sense.
- Effect on cost, price and marginWhat the projected burden means for the cost of purchases, the selling price and the company's margin.
- Technical recommendation and decision calendarThe path that tends to make the most sense, with assumptions and caveats in clear language, and the dates by which each decision must be made.
How it works
- 01
Conversation and profile. We understand the current regime, who the company sells to, who it buys from and how margins look. We agree on scope, timeline and price before we start.
- 02
Data base. We gather the tax and accounting files the company already submits to the tax authorities and check item classification and revenue segregation, so the projection starts from reliable numbers.
- 03
Year-by-year projection. We calculate the four paths from 2027 to 2033, using the rules of Complementary Law 214/2025 and stated assumptions for what is not yet defined, such as the CBS rate.
- 04
Recommendation and calendar. We present the conclusion in plain language, with both scenarios, and redo the projection when a relevant assumption changes, such as the setting of the CBS rate.
The projections are directional estimates, tied to Complementary Law 214/2025 and to the stated assumptions. They guide the decision; they do not replace it. The CBS reference rate for 2027 is still to be set by the Senate, and the IBS rate from 2029 onward will come later. Basis: Complementary Law 214/2025 (articles 343, 344, 346 to 349, 353 and 361 to 364), Complementary Law 224/2025 (article 4), Law 9,718/1998 (articles 13 and 14) and Constitutional Amendment 132/2023. Updated on October 29, 2026. Where a matter requires legal representation, it is hired directly by the client from professionals of their choice.
Frequently asked questions
- Does the reform end Simples, Presumed Profit or Actual Profit?
- No. All three regimes continue to exist. The reform changes the consumption taxes, not how IRPJ and CSLL are calculated.
- Presumed or Actual Profit: what changes in 2027?
- The cumulative PIS and Cofins of Presumed Profit end, and the two regimes begin calculating CBS and IBS the same way, with a right to credit. The choice then depends mainly on IRPJ and CSLL, that is, on the gap between the real margin and the presumed margin.
- Why does the projection run to 2033?
- Because the transition only ends in 2033. Between 2029 and 2032, ICMS and ISS fall and the IBS rises, and the ranking among regimes can flip during that period. Looking only at 2027 does not show this.
- What will the CBS rate be?
- It is not yet defined. The Senate is due to set it by resolution by December 15, 2026, based on calculations from the Federal Court of Accounts (Tribunal de Contas da União). Until then, we work with stated assumptions and redo the projection when the official figure is published.
- Can I change regime mid-year?
- For IRPJ and CSLL, no: the choice holds for the whole year. Under Presumed Profit, it is expressed by paying the first or only installment of the tax. The exception is the decision on IBS and CBS inside or outside the DAS under Simples, which has its own deadlines.
- Does the projection account for the increase in the Presumed Profit presumption?
- Yes. We take the rules in force into account, including the 10% increase in the presumption percentages on the portion of gross revenue above R$ 5 million in the year, provided for in Complementary Law 224/2025.
- What do I need to provide?
- Basically the files the company already submits to the tax authorities and to its accountants, such as tax returns, invoices and bookkeeping records. In the initial conversation we tell you exactly what is needed.
- Does the recommendation hold forever?
- No. It holds for today's profile and rules. That is why the projection is revisited when the company's profile changes or when a relevant rule is defined or changed.
- Does this replace my accountant?
- No. The planning runs alongside the company's accounting team, which remains responsible for the calculations and filings. We deliver the numbers and the recommendation to support the decision.
- Do you guarantee savings?
- No. The projection shows how each path behaves with your company's data, with assumptions and limits explained. The price of the work is agreed before we start.
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Tell us your situation. In thirty minutes, we map what needs to go into the projection, even if the path does not involve Tributum.