Brazil PIS/Cofins sunset: R$140B credit balance hinges on CBS transition rules

Brazil's PIS and Cofins contributions will be replaced by the CBS on January 1, 2027, per Constitutional Amendment 132/2023 and Complementary Law 214/2025. The estimated R$140 billion in outstanding credits for ~100,000 companies will not be voided but require proper accounting and adherence to existing deadlines; court-obtained credits follow separate rules. The transition creates compliance and cash-flow uncertainty for affected firms, with the Receita Federal having flagged issues in June.