Companies have until December 2026 to review their tax calculations for the past five years and ensure that, starting in 2027, any identified PIS and Cofins credits are automatically applied.
This requirement stems from Complementary Law no. 214/2025, which preserved PIS/Pasep and Cofins credits during the transition to the Tax Reform. The Federal Revenue Service, in a statement published on June 3, 2026, clarified that the automatic application of these credits via PER/DCOMP Web will consider only the balances reported in the December 2026 EFD-Contribuições filing.
Regarding this matter, we highlight 3 key points:
1. Without timely bookkeeping, offsetting is no longer automatic: In practice, companies that identify and record PIS and Cofins credits by the deadline for filing contributions will have their balances automatically refunded through PER/DCOMP Web starting in 2027, which will include a specific feature for this purpose. Credits identified after this cutoff date do not, in and of themselves, lose their legal validity. The law does not provide for this consequence, but such credits are excluded from this automatic process and must instead be recognized through an administrative procedure, which is slower and subject to greater scrutiny. The review of the accurate calculation must therefore be completed before December 2026. The goal is to ensure that the identified credits are correctly recorded and follow the automatic process provided for in the transition.
2. Tax Complexity Increases the Potential for Recovery: According to a study by the Brazilian Institute of Planning and Taxation (IBPT), 95% of Brazilian companies pay more in taxes than they owe. This situation reflects the complexity of the Brazilian tax system. A review of the last five years of tax calculations allows companies to identify overpayments, unclaimed credits, and inconsistencies that may lead to tax refunds or offsets.
3. All companies should review their tax calculations, including those that have already done so: This review should not be viewed as a one-time initiative. Companies that have conducted previous analyses also need to reassess the last five years of tax calculations, taking into account new reporting periods, regulatory changes, and operational shifts. This analysis helps identify credits that have not yet been applied and correct inconsistencies that may impact tax refunds.
Reviewing PIS and Cofins calculations helps identify amounts that were overpaid. With bookkeeping required through December 2026, credits will be automatically applied starting in 2027, enabling faster cash flow and avoiding more bureaucratic administrative procedures.
