Article published in Magazine Canal Solar – Vol. 7, No. 5 October/2026
On January 1, 2027, the CBS (Social Contribution on Goods and Services) will fully replace the PIS and Cofins taxes. For energy generators taxed under the Real Profit regime, the transition has a little-discussed effect: assets whose PIS/Cofins credits have already been fully appropriated do not generate CBS, and this increases the effective tax burden of the new contribution for these taxpayers.
Power generation is a capital-intensive activity with low current input costs. In a wind farm, solar farm, or small hydroelectric plant, the bulk of the cost is in machinery and equipment acquired before commissioning.
Many of these companies took advantage of the legal option to claim PIS and Cofins credits on these assets in an accelerated (1/48) or immediate manner, instead of following the depreciation process.
Complementary Law No. 214/2025 preserved credits that are still in effect as of December 31, 2026. However, there is no rule granting CBS credit on goods for which PIS/Cofins credit has already been exhausted.
The choice of accelerated or immediate appropriation was rational: it anticipated cash flow during the implementation phase, when revenue is still low and leverage is high. The result, however, is that a park with five or ten years of operation reaches 2026 without any remaining credit on its main asset.
Two groups are excluded from this reasoning. Projects qualified under REIDI acquired equipment with PIS/Cofins tax suspension and, therefore, without credit. And companies operating under the Presumed Profit regime, subject to the cumulative regime (3,65%), never credited anything; for them, the transition to CBS is a problem of a different nature and magnitude.
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