R.V. Pinheiro Advogados
Executive brief
R.V. Pinheiro Advogados
RV Insights · Issue 02 / 2026

Brazilian Tax Reform · Credit balances

ICMS and PIS/COFINS credits under Brazilian Tax Reform.

Key changes and planning considerations for companies carrying accumulated tax credits through the transition.

The gradual replacement of Brazil’s current system changes the logic for using credits and requires planning to reduce financial loss, approval delays and exposure while old and new regimes coexist.

Key changes and planning considerations for companies carrying accumulated tax credits through the transition.

The gradual replacement of Brazil’s current system changes the logic for using credits and requires planning to reduce financial loss, approval delays and exposure while old and new regimes coexist.

Who should pay attention

  • Companies with recurring ICMS or PIS/COFINS credits
  • Exporters with accumulated balances
  • Businesses relying on credit approval or transfer

Accumulated credits

Companies with recurring balances should map origin, documentation, approval status and use alternatives before current taxes are phased out.

  • Credit inventory and reconciliation
  • Document quality
  • Generation and utilization projections

Exporters

Export exemptions often create structural accumulation. Planning should address refunds, transfers, monetization and working-capital effects.

Transition strategy

Contracts, pricing, tax systems and accounting recognition policies must reflect the timeline and procedures applicable to each credit.

  • ICMS and state-level rules
  • PIS/COFINS and federal procedures
  • Integration with IBS and CBS

Informational demonstration only. It does not address specific situations and is not legal advice.

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