Tax Pills: We've Reached the End of the Series – What to Do Now?

Fourteen pills. Fourteen topics covering the most relevant aspects of the Tax Reform for agribusiness. What begins as information needs to transform into action — because in the tax world, inertia has a cost. Here are the eight priority steps for rural producers and agribusiness companies.

First: confirm the 2024 billing.

Before anything else, individual farmers need to know if they earned R$ 3.6 million or more from agricultural activity in 2024 — considering, in the calculation, the revenue from all legal entities with agricultural activity in which they have a shareholding. If the sum exceeded the limit, the farmer is subject to IBS and CBS taxes from January 1, 2026. Regularizing this situation urgently is the first step.

Second: map your shareholdings.

Every producer with a mixed structure — farm under their personal name, businesses under their corporate name — needs to conduct a complete survey of their holdings in legal entities with agricultural activity. This includes cooperatives of which they are a member, rural holding companies, and storage and marketing companies. The sum of the revenues of these entities can determine their taxpayer status.

Third: check your inputs in Annex IX

Perform a product-by-product analysis of the inputs you use — fertilizers, seeds, pesticides, veterinary medicines. Confirm which ones are listed in Annex IX of Supplementary Law No. 214/2025 and which ones require updated registration with the Ministry of Agriculture to guarantee the reduced tax rate. Unregistered inputs do not qualify for the benefit.

Fourth: Review your business contracts.

Purchase and sale contracts with meatpacking plants, cooperatives, trading companies, and distributors need to reflect the new presumed credit flow. Those who sell to these buyers need to ensure the correct issuance of tax documents; those who buy need to structure the process of appropriating the presumed credit. Contracts that do not address this new dynamic become outdated—and outdated contracts generate conflict.

Fifth: evaluate the voluntary option for the regular regime.

If you are a producer (PF) below the limit and have operations with a large volume of accruable credit—whether from investments in equipment or from exports—it is worth calculating whether the voluntary option for the regular regime is advantageous. The credit that currently remains with the buyer as presumed could be on your balance sheet as actual credit to be offset or reimbursed.

Sixth: Structure the management of the credit balance.

For those who will be taxpayers—whether by obligation or by choice—a credit balance will be a recurring phenomenon. Define from the outset: how will the monthly calculation be done? What is the reimbursement request process? Who on the team is responsible for monitoring this balance? A credit balance without management is idle money—or lost money.

Seventh: Train your team and adjust your systems.

Issuing tax documents in the new format, calculating IBS and CBS, calculating presumed credit, and managing credit balances are new processes that require prepared personnel and systems. Don't wait until 2027 to begin this process—systems need to be tested before operating at full capacity.

Eighth: Seek expert guidance.

Tax reform is genuinely complex. There are open questions, disputed interpretations, and rules whose practical impact will only become clear over the next few years. No producer, no company, no cooperative should navigate this environment without specialized legal and accounting advice in agribusiness taxation.

This series ends here, but the work begins. Tax reform will reshape Brazilian agribusiness over the next seven years. Those who prepare well will have a head start. Those who wait will be left behind.

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• Tax Pills #01: The regulations have arrived – now what?
• Tax Pills #02: The 5 Changes Every Producer Needs to Understand
• Tax Pills #03: Livestock Farming and Tax Reform – What Really Changes?
• Tax Pills #04: Agriculture – What Changes for Those Who Plant?
• Tax Pills #05: Agricultural Inputs – The Reform Changes the Cost of Production
• Tax Pills #06: Individual Farmer - Everything You Need to Know
• Tax Pills #07: Rural Producer as a Legal Entity – How is Your Rural Business Affected?
• Tax Pills #08: Farm registered as an individual (PF) and Company registered as a legal entity (PJ) – A Rule That May Surprise You
• Tax Pills #09: Agricultural Cooperatives – What Changes for Members
• Tax Pills #10: Points That Will Generate Dispute – Litigation in Agriculture
• Tax Pills #11: The Reformation Calendar – When Each Thing Takes Effect
• Tax Pills #12: Credit Balance – Money That May Be Sitting on Your Desk
• Tax Pills #13: We've reached the end of the series – Does Reform Open the Door to Carbon?