Tax Reform and Income Tax: What Should Change in IR
Understand how the Tax Reform (CBS/IBS) interacts with Income Tax (IR), what changes in IRPJ and CSLL, and whether there will be a unified tax base.
Executive Summary
The Tax Reform focused on consumption taxes (ISS, ICMS, PIS, COFINS), but there are collateral changes to corporate Income Tax (IRPJ and CSLL), as well as discussions about how the new CBS/IBS structure coordinates with IR. In this guide, Vivian Sampaio explains what actually changes, what stays the same, and which points still require attention from the financial manager.
What the Tax Reform Already Addressed and What It Left Aside
LC 214/2025 (Tax Reform) focused on replacing:
What was NOT modified by LC 214/2025:
- IRPJ (corporate income tax)
- CSLL (social contribution on net profit)
- IOF (tax on financial operations)
- ITCMD, ITBI (state/municipal taxes on assets)
How CBS and IBS Interact with IR
IR Calculation Base — What Counts In and What Counts Out
The big question for financial managers is: are amounts paid as CBS and IBS deductible for IR purposes?
The short answer is: yes, but with specifics.
CBS and IBS are levied on the value of the transaction — just as PIS and COFINS were. The rules on tax deductibility follow the same logic:
- CBS and IBS paid on operating expenses → deductible as operating cost or expense
- CBS and IBS paid on fixed assets → form part of the acquisition cost (not deducted immediately)
Practical example:
Crediting and the IR Base
A crucial point: CBS and IBS credits do not affect the IRPJ/CSLL calculation base.
- Credits are equity items — recorded as assets under “tax credits to be appropriated”
- They only affect IR once effectively used (offset) or realized (sold)
- If a company has R$ 1 million in CBS/IBS credits, this does not reduce its taxable profit until the credits are used
Effective Changes to IRPJ/CSLL
LC 214/2025 did not directly alter the structure of IRPJ and CSLL, but the new CBS/IBS scenario requires attention on a few points:
1. Base IRPJ Rate
Today, IRPJ has rates of 15% + a 10% surcharge on profit above R$ 240,000/year. As of the writing of this guide, the IRPJ schedule remains unchanged.
2. Interest on Equity (JCP)
JCP is an instrument by which companies can remunerate shareholders with tax deductibility. The reform may change its limits, but there is still no definition.
3. Limits on Sector-Specific Tax Breaks
Some IR tax breaks (Simples Nacional (simplified tax regime), specific regimes) will be reassessed in light of the new CBS+IBS system. This may affect industries that currently rely on IR tax benefits.
Unified Tax Base: Dream or Reality?
One of the reform’s promises was to create a “single tax base” — a system where all taxes are levied on the same calculation base, eliminating double taxation and cumulativity.
In practice:
- CBS and IBS use a different calculation base from IR — CBS/IBS are levied on the transaction value (revenue); IR is levied on profit.
- There is no base unification — at least not at this stage of the reform.
How the Financial Manager Should Prepare
Short Term (2026)
- Separate the analyses — IRPJ/CSLL continues to be calculated on profit, regardless of CBS/IBS
- Review costs — make sure CBS/IBS are correctly classified as operating cost
- Update SPED — the bookkeeping system will need new fields for CBS and IBS
- Assess impacts on covenants — financing contracts that use EBIT or similar metrics may need revising
Medium Term
- Monitor IR changes — if the reform advances to a second phase, there may be changes to IRPJ
- Review capital structure — the interplay between JCP, dividends, and CBS/IBS may shift the optimal structure
- Tax planning — it will be necessary to revisit the mix between Lucro Real (actual-profit regime) and Lucro Presumido (presumed-profit regime) in light of the new taxes
What Stays the Same in IR
Want to understand how the Tax Reform affects your sector? On /napratica, VMAHUB publishes practical guides for companies. For a personalized analysis of your case, talk to our team: [email protected]
Read also:
- Tax Reform 2026: Complete Guide
- CBS: What It Is and How It Replaces PIS/Cofins
- IBS: What It Is and How It Replaces ICMS and ISS
- Individual vs. Company in the reform — how the Tax Reform affects the choice between operating as an individual or as a company.
- Tax planning for the transition — strategies to navigate the coexistence period safely.
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