Lucro Presumido (Presumed-Profit Regime) Under the Tax Reform: Changes and How to Stay Competitive
Understand how Lucro Presumido (presumed-profit regime) companies are affected by the tax reform (LC 214/2025) and whether it is worth staying or switching regimes.
Executive Summary: Lucro Presumido (presumed-profit regime) is a tax regime used by many mid-sized companies whose actual profit must be compared with the margin the government presumes. With the Tax Reform (LC 214/2025), the logic behind this classification needs to be revisited. Understand what changes, when it makes sense to stay, and how to plan the transition.
What Lucro Presumido Is and Who Uses It
Lucro Presumido (presumed-profit regime) is a tax regime that serves as an alternative to Lucro Real (actual-profit regime). Under it, the government presumes that the company earns a profit margin on its revenue (ranging from 1.8% to 32% depending on the activity), and CSLL and IRPJ are levied on that presumed margin. The other contributions (PIS, COFINS, ICMS, ISS) are paid on actual revenue.
It is widely used by service companies, such as consultancies, marketing agencies, and accounting firms, because the presumed margin tends to be higher than the effective profit — leading to lower taxation compared with Lucro Real (actual-profit regime).
With the reform, PIS and Cofins give way to CBS, and ICMS and ISS are gradually replaced by IBS over the transition. The main question is how the presumed margin will continue to interact with these new taxes.
How the Reform Affects Companies Under Lucro Presumido
The transition from Lucro Presumido (presumed-profit regime) to the new system involves multiple layers:
- CBS replacing PIS/Cofins: the contribution on revenue will be replaced by CBS, with its own calculation and crediting rules.
- IBS replacing ICMS/ISS: for service companies, ISS will be absorbed by IBS. The effective rate may differ from the current one, affecting margin and competitiveness.
- Presumed margin: the presumed margin may lose relevance if it is not recalculated for the new system, or it may be retained as the basis for IRPJ and CSLL.
Practical example: An accounting firm in Belo Horizonte bills BRL 600,000 per year. Under Lucro Presumido, the margin for accounting services is 32%, generating a base of BRL 192,000 for CSLL and IRPJ. With the reform, the company will need to reassess the combined weight of CBS and IBS on its revenue to understand whether the regime remains competitive.
When Staying in Lucro Presumido Is Advantageous
Lucro Presumido (presumed-profit regime) remains attractive for companies whose actual expenses are low and whose effective profit is in line with the presumed margin. This is common in:
- Specialized service providers with high profitability
- Companies with a simple structure and few operating costs
- Businesses whose partners prefer a simpler accounting routine
Practical example: A digital agency in Recife bills BRL 900,000 per year with costs of only BRL 200,000 (including the partner’s salary and fixed expenses). The effective profit is BRL 700,000, well above the presumed 32% margin (BRL 288,000). In this case, Lucro Presumido is disadvantageous — the company pays IRPJ/CSLL on a base smaller than its actual profit. Under the reform, it is advisable to migrate to Lucro Real (actual-profit regime) or assess the new classification.
When to Switch to Another Regime
With the reform, companies under Lucro Presumido (presumed-profit regime) should consider:
- Migration to Lucro Real (actual-profit regime): if effective profit is high, it may be worth paying IRPJ/CSLL on actual profit with expense deductions.
- Assessment of Simples Nacional (simplified tax regime): for companies with revenue up to BRL 4,800,000, Simples may be an alternative.
- New simplified classifications: for very small structures, regulation may create simpler alternatives than keeping a CNPJ (company tax ID) in this format.
Planning the Transition
To make the best decision, the business owner should:
- Project costs with CBS and IBS: estimate the weight of the new taxes on revenue.
- Compare with Lucro Real (actual-profit regime): include actual expense deductions in the calculation.
- Assess the cost of compliance: changing regimes carries administrative costs.
- Wait for the regulation: the detailed rules for Lucro Presumido (presumed-profit regime) within the new system still need to be consolidated.
Want to understand how the tax reform affects companies under Lucro Presumido and whether it is worth migrating? On /en/napratica, VMAHUB publishes practical guides for companies. For a personalized analysis of your case, talk to our team: [email protected]
Read also:
- Simples Nacional Under the Tax Reform
- Individual vs. Incorporated (PF x PJ) Under the Tax Reform
- Tax Planning 2025-2027
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