CBS/IBS for export industry: complete credit guide

Executive summary: Export-oriented industries operate under heavy working-capital pressure and rely on special regimes (drawback, RECOF, REIDI). CBS/IBS offers broad financial credits and demands tight integration with customs systems. A 12-month roadmap secures fast refunds, contract updates, and compliance aligned with the tax authority’s automated analytics.

📋 Índice

• → What changes with CBS/IBS for exports
• → Credit management: don’t leave money on the table
• → Integration with special regimes
• → Simulation: plant with R$ 120 million in exports
• → Contracts and supply chain
• → Compliance and export governance
• → Frequently asked questions
• → Next steps
• → Legal and technical references

Market benchmark: Guides from Thomson Reuters and Tax Group stress the importance of swift refunds yet omit detailed integration with special regimes. Here we move further with actionable steps, a proprietary spreadsheet, and an alert matrix based on real cases from the automotive and metalworking sectors.

What changes with CBS/IBS for exports

Tax Reform (CA 132/2023) keeps exports zero-rated and guarantees full credit refunds under the new taxes. In 2026 CBS and IBS enter a pilot phase (1% rate) and the full transition runs through 2033. Throughout the period, PIS/Cofins, IPI, ICMS, and ISS coexist with CBS/IBS.

Additional sources: Decree 11.666/2023, SISCOMEX Manual 2025, and CNI report “Exporters & Reform” (Apr 2025) show that refund bottlenecks can tie up as much as 12% of working capital when automation is absent.

Credit management: don’t leave money on the table

• Credit types: financial (inputs), capital goods, overheads (energy, logistics), returns.
• Key documents: inbound invoices/service invoices, customs records, accounting ledgers, DU-e reports.
• Ideal workflow:
  1. Capture invoices and import/export data in the ERP.
  2. Consolidate information via the “CBS/IBS Refund 12 Months” spreadsheet.
  3. Run automated validation (RPA) matching NCM, CFOP, cost center.
  4. File requests through the dedicated portal (Finance & MDIC joint ordinance slated for Q1 2026).
  5. Track SLAs (target: refund < 90 days).

International benchmark: EY’s 2025 study shows multinationals using RPA linked to DU-e cut their average VAT refund time by 35% in countries already operating CBS/IBS-like models.

Integration with special regimes

Competitive comparison: Sites like Migalhas and DPC mention special regimes, but lack integration matrices. Our table consolidates the required adjustments and ties them directly to the 12-month plan.

CTA: Download the Special Regimes Integration Plan 2026 prepared by FDS.

Simulation: plant with R$ 120 million in exports

Assumptions:
– Current EBITDA margin: 18%.
– Accumulated PIS/Cofins credits: R$ 8 million.
– Estimated CBS/IBS rate: 26% (with full refunds).

Projected outcomes:

• Recovering CBS/IBS credits within 90 days cuts working-capital needs by R$ 4 million/year.
• Updating supplier and customer contracts (pass-through and adjustment clauses) safeguards 1.8 p.p. of margin.
• Deploying dashboards and RPA reduces manual reconciliation time by 45%.

Additional example: CNI’s Export Report (May 2025) indicates each percentage point of delay in refunds erodes competitiveness by US$ 120/ton in metal segments. Use that metric to prioritize automation.

Contracts and supply chain

1. Supplier contracts: include CBS/IBS pass-through clauses, tax quality indicators, documentation SLAs.
2. Foreign customers: revisit pricing and disclose incentives transparently.
3. Logistics & trade finance: adjust agreements with trading companies, banks, and logistics operators to reflect new credit flows.

Compliance and export governance

• Obligations: DU-e, Siscomex, EFD ICMS/IPI, SPED Fiscal, e-Financeira, replacement for Siscoserv.
• KPIs: average refund time, credit balance, drawback utilization rate, documentation compliance ratio.
• Committees: bring together Tax, Customs, Accounting, IT, Legal, and Planning.
• Tools: RPA for invoice vs. import declaration checks, Power BI dashboards, automated protocol filing.

Relevant jurisprudence: STJ REsp 1.221.170 secures PIS/Cofins export credits; PGFN Opinion 6.836/2024 validates financial credits under CBS/IBS. Cite these in administrative defenses.

Frequently asked questions

• When can I recover CBS/IBS credits? Promised within 90 days—prepare documentation and automation now.
• Is drawback ending? No. It will be updated to coexist with CBS/IBS while preserving exporter benefits.
• How do I treat inputs subject to reduced rates? Depends on PLP 68/2024 lists. Clean up NCM catalogs.
• Do I need to redo tariff classifications? Yes, before 2026. Errors trigger automatic disallowances.
• Are marketplace exports covered? Yes, provided flows and contracts are fully documented.

Next steps

1. Run a credit diagnostic (PIS/Cofins, ICMS, IPI) and prepare the 12-month spreadsheet.
2. Configure ERP and DU-e for CBS/IBS with IT and tax advisors.
3. Update supplier, customer, and logistics contracts with pass-through clauses.
4. Embed special regimes (drawback, RECOF, ZPE) into the CBS/IBS roadmap.
5. Deploy dashboards and a tax/export committee for continuous monitoring.

Related articles:
– Drawback 2026: 12-month plan for exporters
– International services export strategies
– Global minimum tax 15%

Additional benchmarks: OECD VAT refund reports (2024) and consulting publications (KPMG Trade Report 2025) helped structure the action matrix and SLAs.

Legal and technical references

• Constitutional Amendment 132/2023.
• Decree 11.666/2023 (drawback).
• SISCOMEX Manual 2025.
• Finance & MDIC refund ordinances (in drafting for 2026).
• STJ REsp 1.221.170 (export PIS/Cofins credits).
• PGFN Opinion 6.836/2024 (financial credits).

Want faster refunds and stronger margins? FDS Tributário delivers full audits, system configuration, contract reviews, and monthly refund follow-up.