Recently, Complementary Law Project No. 63/2025 (PLP 63/2025) was introduced by Senator Laércio Oliveira, proposing the granting of a presumed credit for the Contribution on Goods and Services (CBS) to the service sector as a way to offset the impacts of the recently approved tax reform, starting from the beginning of the transition period.

This measure seeks to balance the effects of the new taxation system on consumption through the dual VAT (CBS and IBS) in the service sector, which historically has labor costs (payroll) as its main operational expense, not subject to credit appropriation under the non-cumulative system of the aforementioned taxes.

It is important to note that the proposal adds paragraphs 12 and 13 to Article 47 of Complementary Law No. 214/2025, instituting a presumed credit equivalent to 60% of the standard CBS rate applied to the value of the transaction recorded in electronic tax documents for companies whose predominant activity is the provision of services, defined as follows: (i) when this activity represents more than 75% of gross revenue according to the CNAE (National Classification of Economic Activities); or (ii) in the case of multiple activities or units, it will be defined by the one that concentrates the highest number of employees, as per the parameters of the social security regulations in Brazil.

Thus, the credit must be highlighted in tax documents and may be used to offset federal taxes administered by the Federal Revenue Service (RFB), enabling a reduction of the tax burden applicable to companies in the sector.

The project has commenced its proceedings in the Federal Senate and is awaiting analysis by the respective committees and the Plenary. It is noteworthy that this proposal complements other legislative initiatives within the scope of tax reform, such as PLP 108/2024, which, among other aspects, establishes the Management Committee of the Tax on Goods and Services (CG-IBS), provides for the administrative tax process, and governs the distribution of collected revenue among federative entities regarding the IBS, as well as the Tax on Transmission Mortis Causa and Donation of Any Assets or Rights (ITCMD).