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New rules of LC nº 214/2025 affect vessel chartering, accumulated credits, and cash flow in the offshore sector.
The Consumption Tax Reform brought significant changes to the oil and gas industry, especially after the creation of IBS and CBS.
Additionally, LC nº 214/2025 defined that these taxes apply to onerous operations with goods and services. Therefore, the legal title used by the parties is no longer decisive.
In practice, this change overcomes old discussions involving ISS, ICMS, leasing, assignment of rights, and service provision. Now, the incidence base is broader.
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As a result, typical contracts in the offshore sector come under the tax radar. Among them are bareboat chartering, time chartering, and voyage chartering.
Furthermore, the rule covers operations with FPSOs, drilling rigs, and maritime support vessels. Therefore, companies in the sector need to review financial impacts.
Chartering can generate recurring credits
In this scenario, the incidence of IBS and CBS on vessel chartering may generate structural credit balances.
This occurs because the amounts paid in these contracts start to generate tax credits. However, in many cases, there will not be enough debits for full absorption.
Consequently, contractors may accumulate credits recurrently. Thus, the focus shifts from just the right to credit.
Now, the focus is on the effective recovery of the amounts. Therefore, reimbursement gains direct weight in cash flow.
Reimbursement deadlines require attention
According to LC nº 214/2025, the IBS Management Committee and the Federal Revenue must analyze requests within 30 days.
However, this deadline applies to taxpayers enrolled in tax compliance programs. Otherwise, the analysis may take up to 180 days.
Moreover, if the Tax Administration does not respond within 30 days, the credit must be reimbursed in the following 15 days.
Therefore, even in the most favorable scenario, the minimum period between the request and payment will be approximately 45 days.
Prior manifestation becomes a decisive point
Even so, the regulations of IBS and CBS created an important step. The taxpayer may express the intention for reimbursement until the last business day of the assessment period.
If this manifestation does not occur, the credit balance will be automatically directed for offsetting future debts.
After that, the formal request must be submitted by the last business day of the month following the assessment period.
Additionally, the company may expressly cancel the previous intention. In this case, the balance becomes available again for future offsetting.
Impact on cash flow may pressure the offshore sector
Therefore, the absence of manifestation may compromise the reimbursement of credits for that period.
For the oil and gas industry, this point is sensitive. After all, chartering operations, exports, and favored regimes can constantly generate accumulated credits.
Thus, the predictability of financial flow, the risk of disallowances, and the operational capacity of the Tax Administration become critical points.
In this way, the sector should closely monitor the deadlines, requests, and procedures provided in the regulation.
After all, in a capital-intensive chain, the recovery of IBS and CBS credits can directly influence the companies’ cash flow.
