If you work in services, technology, marketing or consulting, you know well the pain of the current tax system. We pay PIS, Cofins and ISS, and we rarely manage to use credits on our largest expenses. The old model was designed for classic industry, where you bought steel to make a bolt. For those who buy intelligence, software and services to generate more intelligence and services, the math never added up.
Here lies the best news of Resolution CGIBS No. 6/2026 for the new economy. The tax reform introduces full non-cumulativity and broad financial credit.
What does that mean in plain terms? It means that practically everything your company acquires that was taxed by the IBS will generate credit to offset the tax you have to pay. Unlike the old PIS/Cofins model, which required the expense to be an "essential input" of production, the IBS adopts the financial logic. If the expense is necessary for the company's economic activity and was taxed, it generates credit.
For businesses that are heavy on operating expenses, this changes the financial math. Software subscriptions, cloud services, consultancies, marketing agencies, equipment rentals, technology purchases, assets and intermediate consumption. All of this becomes tax bargaining currency.
First of all, a calendar warning: this is not yet fully in force. Since January 1, 2026, CBS and IBS already appear on the invoice, but in a testing phase, with the IBS at a symbolic rate of 0.1% and no actual collection. The CBS takes on the full rate in 2027, replacing PIS and Cofins, and the IBS rises gradually between 2029 and 2032, until the full model in 2033. In other words, the broad credit we describe here is the rule that consolidates over the transition, and those who structure now start ahead.
And of course the tax authority is no fool. The resolution brings heavy restrictions to prevent abuse. The main filter is "personal use". Articles 62 and 63 make clear that goods and services for personal use and consumption by partners, managers or employees do not generate credit. If you try to pass off the director's luxury car lease or the family's vacation trip as a company expense, the system will flag it. And the "flag" is literal: when a good is characterized as personal use, the credit must be reversed by issuing a fiscal document linked to the acquisition document, identifying, by name and CPF, the individual recipient. In other words, there is an ancillary obligation that exposes whoever took the benefit. And more: the credit is also charged back when the company transfers to third parties goods or services that generated credit on entry.
Didn't get it? Let me explain. In donations in general, you choose: either you tax by market value, as if you had sold at the normal price, or you cancel the credit you used on entry (art. 6, VIII, §2). For related parties, that is, partners, managers, relatives and other connected persons, there is no choice: taxation is mandatory, in an amount equivalent to the IBS on the market value (art. 5, I). And the trigger is not only the donation: a non-onerous supply or one below market value is enough. Selling the company laptop to the partner for R$ 100 falls under the same rule, charging a symbolic amount does not help you escape.
OK, but let's get back to what matters. The revolution here is one of efficiency. Service and technology companies will stop being the weak link of the tax chain. But what is still not entirely clear is the real level of use on borderline expenses. Those that sit in the gray zone between the operational and the employee benefit. The definitive criteria on what characterizes "personal use" in remote work models, for example, will still generate debate. In addition, the refund deadlines (when you accumulate more credits than debits) are already defined, from 30 to 180 days, adjusted by the Selic rate, but the operationalization still depends on acts of the RFB and the CGIBS. But on its own, the news is already good.
Article originally published on GazzConecta.
