The TCU calculated the reference rate and the Senate decides by December 15. How much it weighs in your case depends on the credit, and you can run that calculation now.
Summary The CBS at 11.3% is the reference rate calculated by the TCU for 2027, replacing PIS and Cofins. Comparing it directly to today's 9.25% leads to a wrong calculation because the taxes are computed differently. What will determine how much your company pays is the CBS credit on purchases, not the rate alone.
The headline of the day was "CBS at 11.3%." For those currently paying 9.25% or 3.65% in PIS and Cofins, the first read is a tax increase. We looked at what the number actually means and what it genuinely changes in a company's calculations.
CBS is the Contribuição sobre Bens e Serviços, the federal tax that replaces PIS and Cofins starting January 2027. It is the federal half of the new consumption tax. The other half is the IBS, which replaces ICMS and ISS and phases in gradually through 2033.
What the TCU calculated
At the October 28, 2026 session, the Tribunal de Contas da União (TCU) calculated the CBS reference rate for 2027 at 11.3468%, rounded to 11.3%. The market had projected something close to 8.8%.
The reference rate is the percentage calibrated so that CBS collects the same amount as PIS and Cofins collect today. It is an average for the entire economy. On its own, it does not say how much your company will pay.
THE NUMBER TO KEEP IN MIND 11.3% CBS reference rate in 2027. In 2027 and 2028, the law deducts 0.1 point from that rate, and the CBS charged comes to 11.2%. In the same period, IBS starts at 0.1%. Sources: TCU, session of 10/28/2026; LC 214/2025, art. 347.
What happens before January
10/28: The TCU calculates the reference rate at 11.3%.
By 12/15: The Senate sets the rate by resolution. It may accept the calculation or adjust the assumptions.
No vote: If the Senate does not vote within the deadline, the TCU figure applies.
01/01/2027: CBS replaces PIS and Cofins.
Between the Senate's decision and the first invoice with the full CBS, there are just over two weeks. That is very little time to revise prices, contracts, and systems. That is why the calculation is worth running now, using 11.3%, and adjusting if the number changes.
11.3% against 9.25%: is it an increase?
Comparing the two percentages directly leads to a wrong calculation, because they are computed differently.
PIS and Cofins are calculated inclusive: the tax is part of the price itself on which it applies. CBS is calculated exclusive: it is added on top of the price and does not enter its own base (LC 214/2025, art. 12). Recalculated on an exclusive basis, today's 9.25% is equivalent to roughly 10.2%.
A sale of R$ 100 today, recalculated with CBS
Net value; PIS and Cofins today (9.25%): R$ 90.75; CBS reference rate (11.3%): R$ 90.75
Tax; PIS and Cofins today (9.25%): R$ 9.25 (included within the R$ 100); CBS reference rate (11.3%): R$ 10.25 (added on top of R$ 90.75)
Exclusive equivalent; PIS and Cofins today (9.25%): roughly 10.2%; CBS reference rate (11.3%): 11.3%
Norma calculation: 9.25 ÷ 90.75 = 10.19%. The example assumes the same net value before and after. If the company passes the difference on to the price, the invoice figure changes.
The starting difference, under the non-cumulative regime, is close to 1 percentage point. For your company, what will determine the outcome is something else: the credit.
The credit determines how much you pay
CBS applies to the sale, and you deduct the CBS you paid on purchases. That deduction is the credit. The more credit, the less CBS remains to be paid.
LC 214/2025 broadens the credit relative to today's PIS and Cofins: as a general rule, what you purchase with CBS itemized on the invoice generates a credit, with exceptions such as goods for personal use and consumption. And the credit becomes contingent on the supplier having paid the tax on the transaction (LC 214/2025, art. 47).
COMPANY A
• Sells R$ 100,000 in the month.
• Paid R$ 8,000 in CBS shown on supplier invoices.
• Pays R$ 11,300 minus R$ 8,000: R$ 3,300 in CBS.
COMPANY B
• Sells the same R$ 100,000.
• Paid only R$ 1,000 in CBS shown on invoices.
• Pays R$ 11,300 minus R$ 1,000: R$ 10,300 in CBS.
Illustrative example, using 11.3% on R$ 100,000. Not a 2027 projection.
Same sale, same rate, CBS three times higher. Two questions resolve most of the calculation: who you buy from and how much of your cost comes with an invoice.
The starting point for each company
LC 214/2025 broadens the credit relative to today's PIS and Cofins: as a general rule, what you purchase with CBS itemized on the invoice generates a credit, with exceptions such as goods for personal use and consumption. And the credit becomes contingent on the supplier having paid the tax on the transaction (LC 214/2025, art. 47).
NON-CUMULATIVE 9.25% with credit restricted to inputs. This is the rule under Lucro Real (Laws 10.637/2002 and 10.833/2003). The base changes and the credit becomes broader.
CUMULATIVE 3.65% with no credit. Applies under Lucro Presumido and to part of Lucro Real revenues (Law 9.718/1998; Law 10.833/2003, art. 10). This group has the most urgent calculation to run.
SIMPLES NACIONAL CBS follows the unified payment slip, unless the company opts to calculate it separately under the hybrid regime.
Under the cumulative regime, the change is a shift in level: a low rate with no credit gives way to the full rate with credit. Companies that purchase heavily with invoices may end up with a result similar to today. Those that purchase little will not.
For Simples Nacional, the decision is different and has a deadline: the option for the hybrid regime for the first half of 2027 runs until October 30, 2026. We covered that choice in Tax regime in 2027: Simples, Presumido, or Real?
Service companies: watch the payroll
In a service company, the largest cost is usually payroll. And employee wages do not generate CBS credits. There is little left to deduct, and the company tends to be closer to Company B in the example.
That does not mean every service company will pay more. Some activities have a reduced rate under LC 214/2025, such as healthcare services, with a 60% reduction. And part of a service company's costs comes with an invoice: rent, software, energy, third-party services. The outcome depends on your cost structure, and that is what needs to be measured.
How to prepare in five steps
1. Separate revenues by today's PIS and Cofins regime. Cumulative, non-cumulative, or Simples. That is the starting point for the comparison.
2. Identify the purchases that will generate credit. Suppliers, amounts, and whether they issue invoices with CBS itemized. A Simples Nacional supplier generally generates a smaller credit.
4. Review prices and contracts. Long-term contracts need a tax-change adjustment clause. Without one, the difference comes out of your margin.
5. Check your system and invoice setup. Records, the invoice issuer, and the CBS line item on the invoice all need to be ready by January 1.
Step 3 is the one that most changes the answer for those who thought they already knew. A company under Lucro Presumido with heavy purchasing may find the result is similar to today. Another, with payroll as nearly all of its cost, finds it needs to revise prices before January.
Article originally published at Norma Contábil.
