Brazil tax reform to impact Lucro Presumido regime by 2027

The Brazilian tax reform is set to significantly alter the Lucro Presumido regime starting in 2027. While the method for calculating IRPJ and CSLL will remain unchanged under Complementary Law 214/2025, the PIS and Cofins taxes will be replaced by the Contribution on Goods and Services (CBS).

Unlike the current cumulative system used in Lucro Presumido, the new CBS will be based on value-added, allowing for tax credits. This shift may impact service companies more heavily, as payroll costs typically do not generate credits, whereas industries and commerce may benefit from credits on inputs. Experts suggest that companies should evaluate whether transitioning to the Lucro Real regime might become more advantageous due to these new credit mechanisms.

Additionally, businesses operating under Lucro Presumido may have opportunities to recover overpaid taxes from the last five years. Key areas for potential recovery include the calculation base of PIS and Cofins, social security contributions paid on indemnity-natured payments, and errors in applying the correct presumption percentage based on business activity.