Brazil's tax authority reassures companies that PIS/Cofins credits worth R$140 billion won't disappear in the shift to a new consumption tax—they can be offset, refunded, or used against other federal levies.
Brazil’s tax administration, the Federal Revenue Service (RFB) has clarified on 3 June 2026 that existing PIS/Pasep and Cofins tax credits will remain valid and usable even after these contributions phase out with the introduction of the Contribution on Goods and Services (CBS) in January 2027. According to Complementary Law No. 214/2025 of 16 January 2025, taxpayers won’t lose their accrued credits during this shift.
How to use PIS/Pasep and Cofins Credits
Companies holding these credits have three options:
- Offset CBS debts directly against their new contribution liabilities
- Request cash reimbursement of unused credits
- Offset against other federal taxes administered by the Brazilian Federal Revenue Service
The critical requirement: credits must meet the eligibility conditions that were in force when they were generated. This means companies need to have complied with all relevant rules at the time the credits arose and when they request to use them.
This protection applies to both credits already on the books and any new credits companies acquire between now and the CBS transition in January 2027.
The scale of Brazil’s credit pool
Roughly 100,000 companies currently hold PIS/Cofins credits worth an estimated BRL 140 billion. The distribution is skewed toward smaller balances: 70 per cent of companies hold less than BRL 100,000, while 90% have under BRL 1 million in credits. However, the tax authority identified discrepancies affecting about 12,000 companies—representing approximately BRL 44 billion—and will contact these taxpayers directly to regularise their credit declarations.
What’s next
The Federal Revenue Service (RFB) has positioned these measures as part of a broader commitment to ensuring a transparent, predictable transition to CBS. Taxpayers with flagged accounts can expect guidance on correcting their EFD-Contribuições filings before the January 2027 deadline.
