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Opinion Article

Tax reform and its impact on the solar energy sector

We will have to live with both systems, the old and the new, until the end of 2032.

Tax reform and its impact on the solar energy sector

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Article published in the Magazine Canal Solar. Click here and download now for free!

The tax reform on goods and services was finally approved after the approval of Constitutional Amendment No. 132, of December 20, 2023, which changed the National Tax System. Given the profound change, several provisions need to be regulated by Complementary Law, which finally occurred, and culminated in Law No. 214, of January 16, 2025.

The first phase of the tax reform changed taxes on goods and services, replacing PIS, COFINS and IPI with CBS; and ICMS and ISS with IBS, in addition to creating the selective tax, IS. The intention of the reform is to make taxation more transparent and easier by establishing taxes on value added, a model used by most countries.

These and other general concepts can be analyzed by link from the Ministry of Finance, which summarizes the most general points of the tax reform. The changes are substantial and therefore require a transition over the next few years.

As can be seen in the table below, until the end of 2032 we will have to live with both systems, the old and the new. The purpose of this article is to provide initial impressions on tax impacts in the solar energy sector, but not in an exhaustive manner, as the market is very broad when all its agents are identified.

From the outset, it is worth noting that IS does not apply to electricity, therefore, issues related to this tax will not be addressed. We have separated it into some main topics to help the reader with what we intend to analyze.

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The opinions and information expressed are the sole responsibility of the author and do not necessarily represent the official position of the author. Canal Solar.

Einar Tribuci
About the Author
Einar Tribuci

Professor of the course Taxes on Consumption and Generation of Electrical Energy at Canal Solar. Graduated in Law from São Judas Tadeu University in São Paulo, and holds a specialization in Tax Law from the Pontifical Catholic University of São Paulo. With a career spanning over 20 years, Tribuci has extensive experience in tax consulting and planning, working on tax reviews for medium and large-sized companies. He is the owner and partner of the law firm Tribuci Advogados.

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