Tax Reform: The EFD-Contribuições as the key to utilizing PIS/Cofins credits

Companies should conduct an EFD-Contribuições review to identify corrections, make adjustments, and accurately determine recoverable credits

By Marluci Azevedo

The Contribution on Goods and Services (CBS), by replacing PIS and Cofins as of January 1, 2027, introduces a new dynamic in the utilization of credit balances. Companies and their managers need to understand the impact of this now and how the EFD-Contribuições plays a fundamental role in this new phase.

As guided by the Federal Revenue Service, although PIS and Cofins are scheduled to be phased out starting in 2027, the EFD-Contribuições will not be immediately discontinued. This is because this ancillary obligation will be used to manage the remaining credit balances and to meet the legal deadlines for audits and the correction of information.

It is important to emphasize that companies will not lose their accumulated PIS/Cofins credit balances. These credits may be used to offset CBS liabilities, reimbursed in cash, or offset against other federal taxes.

The use of these credits will be managed through PER/DCOMP Web, which will feature a new mechanism: the Credit Utilization Request (PUC). Through this new feature, companies will report how they intend to use the accumulated PIS and Cofins credit balances through December 31, 2026.

Relationship Between the Credit Utilization Request and the EFD-Contributions

There is one point to note: the balance reported in the EFD-Contributions will be automatically retrieved. The credit balance to be included in Records 1100 (PIS) and 1500 (Cofins) for the December 2026 reporting period will be the data retrieved by PER/DCOMP Web.

As a result, this bookkeeping record takes on greater importance, proving to be an essential document in this new phase. In other words, it is the EFD-Contributions—specifically its Block 1000—that will contain this highly relevant tax information, which has the potential to impact the company’s cash flow.

In this context, the quality of the recorded data will be critical for the business. Errors, omissions, or inconsistencies will prevent the offsetting or reimbursement of credits. Therefore, this ancillary obligation requires special technical oversight to avoid exposure to risks.

What to do now to ensure the recovery of PIS/Cofins Credits

It is common to find errors in Block 1000 of the EFD-Contribuições, whether due to the aggregation of balances from different accounting periods, discrepancies with Block M, incorrect entries of untimely credits, or other errors. However, during the transition to the new tax model, these discrepancies carry greater weight, compromising the credit recovery process.

In light of this change, companies must immediately focus on addressing and correcting the EFDs, appropriating untimely credits, and cleaning up Block 1000 by conducting a comprehensive tax audit of the return.

Here are some recommended actions:

Support for the strategy to utilize PIS/Cofins credit balances

Ideally, the company should now have access to an expert assessment of the quality of Records 1100 and 1500—with the necessary cross-checks already performed—as well as support for any required adjustments. This assessment should be viewed as a window of opportunity on the path to transitioning to the CBS and to this new phase brought about by the Tax Reform.

Domingues e Pinho Contadores provides this technical review, assisting businesses with data scanning, reconciliation, the identification of recoverable credits, and the implementation of best tax practices. Count on our support: dpc@dpc.com.br.