Brazil confirms PIS/COFINS credits remain usable after CBS shift

The Federal Revenue Service (Receita Federal) clarified in June 2026 that accumulated PIS and COFINS credits will not be extinguished when the new Contribution on Goods and Services (CBS) replaces the two taxes in 2027. Companies can use the credits to offset CBS liabilities, receive cash refunds through PER/DCOMP, or apply them against other federal taxes. The agency disclosed that roughly 100,000 firms hold about R$140 billion in credits, with divergences identified in about 12,000 companies covering R$44 billion.

The reforms also emphasize the non‑cumulativity principle of CBS and the upcoming IBS, mandated by the Constitution and Law 214/2025. Credits must be linked to extinguished prior‑period debts, supported by proper fiscal documents, and not prohibited by law, as set out in article 47 of the law. Authorities warn that longstanding tax‑contestation habits could impede correct application, urging firms to adhere to the new technical rules to preserve fiscal neutrality and avoid enforcement risks.