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Tributum

Tax & Reform

The transition to CBS and IBS has already begun. It brings short deadlines, credits that can be lost and decisions that change your company's competitiveness.

The calendar that matters

  1. 2026

    Test year: current taxes continue; CBS (0.9%) and IBS (0.1%) are shown on invoices and offset against PIS/Cofins.

  2. 2027–2028

    PIS and Cofins end, including on imports; full CBS; IPI reduced to zero, except for products with incentivized manufacturing in the Manaus Free Trade Zone; the Selective Tax begins; IBS at 0.1%.

  3. 2029–2032

    ICMS and ISS shrink gradually and IBS grows; ICMS incentives last only until 2032.

  4. 2033

    ICMS and ISS are phased out; full CBS and IBS system.

Basis: Constitutional Amendment 132/2023, Complementary Law 214/2025 and Complementary Law 227/2026. Updated on October 23, 2026.

Decisions with deadlines

  • The 2027 switchover: presumed CBS credit on inventory

    Companies under the regular CBS regime will be able to claim a presumed credit on inventory held on January 1, 2027, for example those that were under the cumulative PIS/Cofins regime in 2026. We do the switchover inventory, the calculation and the required documentation.

  • Tax planning for the transition

    A projection of your tax burden under each possible regime, year by year from 2027 to 2033, built from the company's own tax files, to show the year in which the best choice changes.

  • ICMS benefits Compensation Fund

    Companies with onerous ICMS benefits granted up to May 31, 2023 must register by December 31, 2028. We prepare the technical file and the calculations for each benefit.

Basis: Constitutional Amendment 132/2023, Complementary Law 214/2025 and Complementary Law 227/2026. Updated on October 23, 2026.

Ongoing strategy

  • ICMS credit desk

    Credit balances existing on December 31, 2032 will be offset against IBS in up to 240 monthly installments. We map them, organize them for approval and assess the use and transfer alternatives each state allows.

  • Strategic ICMS

    Imports at 4% on interstate sales, DIFAL, tax substitution and special regimes, focused on cash and competitiveness — including the effect of each tax on price and margin.

  • Recovery of federal and social security credits

    A review of what was overpaid in the last five years, based on the files your company has already filed, in the cases the Federal Revenue Service recognizes, with the documentation the administrative request requires.

  • Tax classification of goods

    A line-by-line review of your product register — by NCM, GTIN or description — with the tax treatment expected today and the IBS and CBS classification, so the company reaches the transition with the right register.

  • Ancillary tax obligations audit

    Electronic review of SPED and other filings before transmission, using the same cross-checks that the federal and state tax authorities run afterwards — and correction of the files while there is still time.

  • Transfer pricing

    Arm's-length pricing policies and documentation for transactions with related parties abroad (Law 14,596/2023).

  • Recurring tax compliance

    Monthly monitoring of obligations, tax standing and rule changes, with documents captured straight from official sources, with no manual sending.

Basis: Constitutional Amendment 132/2023, Complementary Law 214/2025 and Complementary Law 227/2026. Updated on October 23, 2026.

Experience

What has already been reviewed

2019–2022

Between 2019 and 2022, Tributum carried out tax reviews for about thirty retail companies in Brazil's Northeast: supermarkets, pharmacies, auto parts shops, convenience stores and gas stations. The work covered PIS/Cofins on single-phase products and electricity, ICMS-ST, corporate income tax (IRPJ/CSLL) and social security (INSS), under Simples Nacional and presumed profit.

≈ 30
companies analyzed
≈ 70%
of completed analyses found credit
R$ 1.5 M
in credits identified
R$ 1.9 M
in tax risks identified before an audit
R$ 3.4 M
in opportunities and risks mapped
How what was mapped breaks down

R$3,446,520

Credits identified
R$ 1.5 M44 %
Tax risks identified before an audit
R$ 1.9 M56 %

Credit is what the company overpaid and can recover. Risk is what it may be underpaying, which, corrected on its own initiative, does not turn into an assessment.

Some of the work

  • Supermarket group

    two stores, Paraíba

    R$ 3.1 million mapped and validated by the company's accounting: R$ 1.18 million in credits, mostly PIS/Cofins on single-phase products, and R$ 1.9 million in tax risks to regularize before any assessment.

  • Supermarket

    Paraíba

    R$ 115 thousand of PIS/Cofins overpaid, identified and amended for offsetting, plus a R$ 5.4 thousand refund paid by the Revenue Service.

  • Pharmacy

    R$ 69 thousand in credits from almost five years of filings, from 2015 to 2020, with a refund notified by the Revenue Service.

  • Auto repair and parts

    R$ 68 thousand of PIS/Cofins on single-phase products identified. The credits were used by the Revenue Service to settle the company's own debts, and an overdue payment slip fell by about R$ 5 thousand.

  • Retail trade

    Paraíba

    R$ 5.4 thousand refunded to the account by the Revenue Service, about five weeks after the request.

A review is also protection

Every review looks at both sides of the calculation: what the company overpaid and what it may be underpaying. Finding a risk before an audit lets the company correct it on its own initiative. At the federal level, the ex officio fine starts at 75% of the tax, and spontaneous regularization before any tax procedure removes that fine, under article 138 of the National Tax Code.

When there is no credit

Eight completed analyses found no credit to recover. In all of them, the company received the technical report at no cost. A review that finds nothing also answers a question.

Past results do not guarantee future results. Each case depends on the documentation available and the legislation applicable to the period.