Tax Reform and Technology Companies: Adaptation of Controllership to the New Tax Credits Model

Patrícia Mafaldo Nunes; Letícia Maria Faleiro Nascimento

DOI: 10.22167/2675-6528-202603367

Article derived from a Course Conclusion Work (TCC), with content based on the student’s original work and adapted to the editorial format of the E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by Instituto Pecege for textual synthesis and organization.

Summary

The Brazilian Tax Reform, instituted by Constitutional Amendment No. 132/2023 and regulated by Complementary Law No. 214/2025, altered consumption taxation, replacing taxes with the Tax on Goods and Services (IBS) and the Social Contribution on Goods and Services (CBS), under the principle of full non-cumulativeness. The study aimed to describe the main challenges perceived by controlling professionals in technology companies in adapting to the new model of non-cumulativeness and tax credit calculation. An applied, descriptive research was conducted with a mixed approach (qualitative-quantitative), through a field survey. Data were collected from 15 controlling or tax management professionals, using a structured questionnaire. The responses were analyzed by frequency distribution and thematic content analysis. The results revealed that professionals perceive the Reform as an event of multifunctional impact, demanding revisions in Enterprise Resource Planning (ERP) systems, tax credit calculation criteria, team training, and interdepartmental integration. The limitation of credit utilization on labor costs emerged as a specific structural challenge for the sector. The strengthening of the controlling function’s strategic role in the tax transition was observed, especially in pricing, tax planning, and contracting structure, contributing to the debate on the managerial and operational implications of the Tax Reform.

Keywords: controlling; tax credits; technology companies; non-cumulative; tax reform.

1. Introduction

The Brazilian Tax Reform, established by Constitutional Amendment No. 132/2023 and regulated by Complementary Law No. 214/2025, represents one of the most significant structural changes in the country’s fiscal system. The project aims to simplify the complex consumption taxation, which has historically been marked by a diversity of regulatory bodies, nomenclatures, rates, and differentiated treatments, making control difficult for both companies and the tax authorities themselves (Buzatto, 2022).

The essence of the reform lies in the replacement of federal taxes such as PIS and COFINS, the state tax ICMS, and the municipal ISS by the Social Contribution on Goods and Services (CBS) and the Tax on Goods and Services (IBS), both of federal competence. This transition brings the Brazilian tax system closer to the Value Added Tax (VAT) model, widely adopted in other countries. The central characteristic of VAT is the application of the principle of full non-cumulativeness, which, despite being associated with a high tax burden and greater operational complexity, tends to favor the free circulation of goods and services, overcoming the limitations of cumulative models (Moreira, 2009).

However, the Brazilian experience with non-cumulativeness has revealed significant practical restrictions. Historically, credit utilization has been limited to inputs directly related to the production process, disregarding costs relevant to certain economic activities (Appy, 2015). Only ICMS can be considered fully non-cumulative, while PIS, COFINS, and ISS apply the principle partially or not at all. These limitations demonstrate that, despite the conceptual advancement of the VAT-inspired model, the operationalization of non-cumulativeness in Brazil still poses considerable challenges, especially from a sectoral perspective.

The services sector, particularly the technology segment, is one of the most sensitive to the effects of the Tax Reform, due to its current system’s framework. The taxation of this sector focuses on the (Municipal) Service Tax (ISS), a cumulative tax that does not allow for the appropriation of credits along the production chain. Within the scope of PIS and COFINS, even in non-cumulative regimes, credit utilization is restricted to inputs directly linked to the product, following the physical input criterion, excluding a relevant portion of the costs of service-providing companies (Appy, 2015). Furthermore, typical activities of the sector, such as software licensing, remain subject to the cumulative regime, with reduced rates but no possibility of credit (Brasil, 2022). Added to this is the fact that the cost structure of technology companies is mainly composed of specialized labor, which is not included in the tax burden base (Brasil, 2025).

In this context, the extinction of ISS, PIS, and COFINS, and their replacement by IBS and CBS — both guided by the principle of full non-cumulativeness and a single rate initially estimated at a high level (Brazil, 2024) — tends to generate significant impacts in the technology sector. This affects the effective tax burden, the credit calculation structure, and tax planning. Although the expansion of the right to credit on acquisitions represents a conceptual advance, the limited capacity to generate credits in activities intensive in human capital may result in asymmetric effects. Controlling assumes a central role in this adaptation process, concentrating essential economic and financial information to understand the current situation and project future developments (Araújo and Carmo, 2022). It is up to controlling to interpret regulatory changes, evaluate impacts, revise cost criteria, and support strategic planning.

In recent years, several studies have analyzed the potential impacts of the Brazilian Tax Reform from different perspectives. Buzatto and Cavalcante (2022) investigated the redistributive effects of consumption taxation. Nascimento and De Morais (2024) analyzed the main changes and their socioeconomic impacts, highlighting sectoral asymmetries. Lima (2024) evaluated the effects of the reform on small and medium-sized service providers. Macedo and Monteiro (2024) analyzed the impacts for micro and small businesses in the Simples Nacional, and Dos Santos and De Oliveira Jurubeba (2025) evaluated the taxation of Simples Nacional in light of the reform, pointing out regulatory gaps.

Although these studies contribute to the understanding of the systemic and macroeconomic effects of the Tax Reform, they focus on fiscal and redistributive impact approaches, dedicating limited attention to the managerial and operational implications of tax changes in the internal environment of organizations. In this sense, a gap is observed regarding the analysis of the managerial and operational implications of tax changes in the internal environment of organizations, specifically concerning the role of controlling in the interpretation, operationalization, and management of the economic and financial impacts arising from the adoption of full non-cumulativeness, especially in sectors intensive in human capital. None of the reviewed studies investigated the perception of controlling professionals about the practical challenges of adapting to the new tax model, nor did they use a field survey to collect primary data from this audience (Da Silva, 2023).

This study is justified by the need to understand how the structural changes of the Tax Reform go beyond the normative sphere, directly impacting the internal management, calculation, and strategic planning processes of organizations. Technology companies, being intensive in human capital, face a specific scenario that demands qualified action from controlling departments, an aspect still little explored in the literature. Furthermore, the gradual transition period foreseen until 2033 makes it urgent to understand the practical challenges faced by professionals in the field, contributing to fill this gap with primary empirical evidence. Given this scenario, the general objective of the study was to describe the main challenges perceived by controlling professionals in technology companies in adapting to the new model of non-cumulative taxation and calculation of tax credits arising from the Tax Reform.

2. Material and Methods

The research was applied in nature, seeking to understand a practical and contemporary phenomenon with direct implications for organizational management, according to Gil’s (2017) classification. A mixed methodological approach was adopted, combining qualitative and quantitative perspectives, characterized by the integration of data for the interpretation of specific phenomena and behaviors of the investigated group (Marconi and Lakatos, 2017). Regarding objectives, the study was classified as descriptive, aiming to systematically characterize the perceptions and practices of controlling professionals in the face of tax changes (Gil, 2017).

The research design consisted of a field survey, or “survey”, a procedure used to collect information directly from respondents about their opinions and perceptions (Gil, 2017). The unit of analysis comprised controllership or tax management professionals. The total sample consisted of 15 respondents, 10 belonging to the main target group, working in technology sector companies, and 5 to a contrast group, from other sectors.

Participant selection was conducted through non-probabilistic convenience sampling, with respondents being accessed through the researcher’s professional networks. The criterion for the contrast group was working in controlling or fiscal management areas outside the technology sector. Data collection was carried out during the period from February to March 2026. The sample size of the target group was based on the criterion of qualitative sufficiency, as recommended by Gil (2017).

As a data collection instrument, a structured questionnaire was used, composed of closed multiple-choice questions and complementary open-ended questions. The closed questions allowed for the standardization of responses, while the open-ended questions captured respondents’ perceptions and justifications. The research form was developed based on the study’s theoretical framework, considering the normative milestones of consumption taxation and the changes introduced by the Tax Reform.

Normative Instruction No. 2.121/2022 and Complementary Law No. 214/2025 were used as references, in addition to contributions from the literature on non-cumulativeness and the role of controllership, such as Moreira (2009), Appy (2015), and Da Silva (2023). The instrument’s questions were constructed in direct correspondence with the specific objectives of the study. The instrument was submitted for content validation by the advisor and for a pre-test with two professionals with compatible profiles, maintaining its original form.

The questionnaire application occurred through the “Google Forms” platform, in digital format, with access via electronic link, enabling remote completion and automatic registration of responses. At the opening of the questionnaire, the Free and Informed Consent Term (TCLE) was presented to each respondent. The TCLE informed the objective of the research, the identity of the researcher, the course of study affiliation, and the guarantee of confidentiality of individual information, ensuring the necessary ethical care.

The data collected from the closed-ended questions were tabulated in a spreadsheet, using the software “Microsoft Excel”, and analyzed through frequency distribution, without any intention of statistical inference. The responses to the open-ended questions were subjected to content analysis with thematic categorization, according to Bardin (2011). This technique allowed for the systematic organization of data based on the identification of recurring themes. Secondary sources, such as consultancy reports and official documents, were used as technical and normative support.

3. Results and Discussion

This section details and analyzes the results obtained from the responses to the questionnaire applied to fifteen professionals, whose data were collected between February and March 2026. Information from closed-ended questions was described through frequencies, while open-ended responses were interpreted by content analysis and thematic categorization, according to Bardin’s (2011) approach. The structure for presenting the results follows a deliberate analytical sequence, organized into five thematic blocks, each corresponding to one or more specific study objectives, allowing for a progressive interpretative construction of the research findings.

The analytical path begins with the characterization of the respondents’ profile and the cost structure of the companies in which they work, providing the necessary context for subsequent analyses. It then moves on to professionals’ perceptions of the changes introduced by the Tax Reform, the impacts on internal processes for calculating credits and tax planning, and the operational challenges faced by controlling departments. Finally, the section culminates in the analysis of the strategic role of controlling in supporting decision-making, seeking to respond to the study’s general objective of describing the main challenges perceived by controlling professionals in technology companies in adapting to the new non-cumulative model and the calculation of tax credits, based on the collected data.

Respondent profile and cost structure

The characterization of the respondents’ profile and the cost structure of the companies in which they operate, focusing on the representativeness of the payroll, constituted the first block of analysis. Of the fifteen participants, ten worked directly in the controlling or tax management area of technology sector companies, forming the target group of the research. The remaining five respondents, from other sectors, were included to offer a contrast and highlight the sector-specific nature of the impacts investigated by the research.

Regarding the length of time working in the field, the target group demonstrated a heterogeneous profile. It was found that half of the professionals had accumulated more than three years of experience, which gives substantial relevance to the perceptions collected about the practical implications of the Tax Reform on controlling processes. This diversity of experience enriches the analysis by incorporating different perspectives on the complexity and challenges of the tax transition in the technology sector.

The analysis of the representativeness of payroll in the companies’ cost structure revealed that, for seven out of ten respondents in the target group, payroll and labor charges represented between 21% and 60% of the total cost. It is noteworthy that no respondent from the target group indicated that the payroll’s share exceeded 60% of total costs, which may reflect both the diversity of business models within the technology sector and the increasing use of alternative hiring structures, such as the provision of services by legal entities, a theme that emerged recurrently in the open-ended responses.

This concentration of personnel costs has direct consequences on the utilization of credits in the new tax model. Lima (2024) had already demonstrated that service-providing companies, by having fewer deductible inputs compared to industry, tend to face a real increase in the tax burden after the reform, even if the system nominally promises neutrality. In this scenario, management accounting is urged to perform simulations of the effective tax burden, considering different contractual compositions of the workforce, such as the relationship between CLT contracts and contracts with legal entities, in order to support strategic decisions about personnel structure that minimize tax impact without compromising legal compliance.

The results confirm the study’s central premise that technology companies have a cost structure with a significant share of human capital. This finding aligns with Appy’s (2015) argument, which points out how the physical credit criterion, historically adopted in PIS and COFINS, excludes a significant portion of the costs of service-providing companies, generating sectoral asymmetries in the operationalization of non-cumulativeness. The limitation of credit utilization on labor costs, a restriction already present in the previous regime and which remains prohibited in the new model of the Tax Reform, constitutes a specific structural challenge for the technology segment, which may see its tax burden increased due to the rise in effective rates on revenue without due compensation of credits on its main cost.

In contrast, respondents from other sectors, who do not operate in the technology segment, indicated a higher concentration of payroll in the range of up to 20% of the total cost. This data reinforces the sectorally differentiated nature of the impact studied, corroborating the conclusions of Nascimento and De Morais (2024), who emphasize the need for greater attention to sectoral asymmetries in the analysis of the effects of the Tax Reform. The comparison between the groups highlights that cost structure is a determining factor in the perception and impact of tax changes.

Perception of the changes introduced by the Tax Reform

The second analysis block investigated respondents’ perception of the relevance of the changes introduced by the Tax Reform in the non-cumulative model applicable to technology companies. The majority of respondents agreed on the relevance of the changes, indicating that the Tax Reform is widely perceived as an event of significant impact. However, four respondents from the target group stated they had no formed opinion, which may reflect the regulatory uncertainty still present in the transition process.

Complementary Law No. 214/2025, which regulates the Tax Reform, was published in January 2025, and its full implementation is scheduled to occur gradually until 2033 (Brazil, 2025). This prolonged transition and the absence of complementary regulation in several areas, as identified by Dos Santos and De Oliveira Jurubeba (2025), contribute to a state of uncertainty that hinders tax planning and may lead to the postponement of adaptation decisions. In this context, controlling can adopt a proactive stance of regulatory monitoring, structuring a calendar for tracking complementary regulations to reduce reaction time and anticipate impacts on cash flow and operating margins.

The content analysis of the open-ended responses allowed for the identification of three recurring thematic categories regarding the examples of changes perceived as most relevant. The first category, “Expansion of the right to credit,” was the most recurrent theme, with respondents highlighting the possibility of utilizing credits on services and inputs that previously did not generate credit. Expenses with cloud services, “software” licensing, “SaaS” tools, and IT outsourcing were specifically cited as acquisitions that will now generate IBS and CBS credits, unlike the previous model.

A respondent from the target group synthesized this perception by stating that “the new model with CBS and IBS expands the right to credits, including on services and expenses that previously did not generate credit, which tends to directly impact this sector, which is intensive in services and technology.” This expansion of the right to credit on intangible inputs represents a concrete opportunity to reduce the effective tax burden. However, its materialization depends directly on the controller’s ability to map, classify, and validate eligible operations for credit in the new model, requiring alignment of accounting practices with the new tax rules, as highlighted by Nascimento and De Morais (2024).

The controller’s office must therefore prepare a detailed report of the expenses with digital and technological services currently incurred, assessing which of them will generate credit starting in 2027. This estimate of the positive financial impact of the credit expansion should be incorporated into the company’s budgetary planning, allowing for more effective resource management and a more accurate projection of future tax burden.

The second category, “Increase in the effective tax burden and complexity of the transition”, revealed that some respondents pointed out that, despite the expansion of the right to credit, the increase in the nominal rate of IBS and CBS may result in an increase in the effective tax burden. This concern is particularly relevant for companies whose usable credits do not offset the increase in the tax rate. One respondent observed that “the first impact is on the immediate increase in the tax burden, the second impact is on the expansion of credit-taking possibilities, which, well controlled, can minimize the effect of the increase in the tax burden.”

This perception is consistent with the findings of Lima (2024), who demonstrated, through simulations, that service-providing companies under the Presumed Profit regime could experience an increase in their effective tax burden from 18.2% of revenue to potentially higher levels with the application of estimated IBS and CBS rates, depending on the volume of usable credits generated in the supply chain. For technology companies, whose main cost is labor, which remains outside the credit base, the compensation from the expansion of credits on other inputs tends to be only partial. It is important to note that, although there is a convergence of meaning, Lima’s (2024) data are quantitative, while those of the present study are subjective perceptions, which requires caution in direct interpretation.

In this context, the controlling department must prepare projections of the effective tax burden under different tax rate scenarios, considering the estimates from the Technical Note of the Ministry of Finance (Brazil, 2024). This proactive approach is crucial for evaluating the real impact on margins and supporting pricing and contractual structure decisions in advance of the full transition period, ensuring the company is prepared for fiscal changes.

The third category, “Impact on hiring structure decisions,” emerged from the association of credit limitation on labor costs, by two respondents from the target group, with the incentive for so-called “pejotization” as a tax adjustment strategy. This perception highlights that changes in the non-cumulative model transcend the fiscal sphere, reaching strategic decisions on people management and organizational structure. This finding had not been identified in the studies reviewed in the literature, representing a specific contribution of the present study to the debate on Tax Reform.

These results dialogue with the argumentation of Buzatto and Cavalcante (2022), who point out that the transition to the VAT model tends to produce heterogeneous redistributive effects between sectors. They also connect with the conclusions of Macedo and Monteiro (2024), who identified that the nominal expansion of the right to credit does not always translate into effective gain for all company profiles, depending on the composition of the cost structure. The perception of controlling professionals reinforces the need for an in-depth analysis of the implications of the reform for people management and the hiring structure.

Impacts of the new model on the calculation processes

The third block investigated respondents’ perception of the impacts of the new taxation model on internal processes of credit calculation and tax planning, as well as on the asymmetry of impacts between sectors. All respondents recognized that the new non-cumulative model generates differentiated and relevant impacts for companies intensive in human capital compared to sectors with higher costs of physical inputs. The absence of responses indicating no differentiated impact constitutes a relevant finding, indicating that sectoral asymmetry is broadly perceived, even by professionals who do not directly work in the technology sector.

Regarding the impact of credit limitation on labor costs in the company, six out of ten respondents from the target group indicated that this limitation generates impacts that require strategy revision. This result reinforces the relevance of the topic for the investigated segment and is compatible with Appy’s (2015) warning that the exclusion of labor costs from the credit base tends to generate regressive effects on capital-intensive sectors. The controller’s office should, therefore, treat this limitation as a permanent structural risk, and not just as a one-time adjustment for the transition period.

As possible mitigation strategies, the review of the contracting structure and the optimization of the use of credits on non-human inputs were pointed out by respondents in the category of impact on contracting structure decisions, which reinforces the coherence between the different results sections. The analysis of open-ended responses revealed two additional impact categories. The first, “Review of the supplier chain and contracting strategy”, indicated the need to re-evaluate the supplier chain and contracting criteria in response to the limitation of credits on labor.

A respondent with over twelve years of experience in the sector detailed the need to “revisit the entire supply chain and suppliers and evaluate the full potential for credit utilization”, in addition to reviewing “the pricing strategy” and “user information for billing compliant with the new issues of the reform.” A concrete example of this challenge is the renegotiation of contracts with suppliers of cloud services and “software” licensing, whose fiscal documentation needs to be adapted to enable the utilization of IBS/CBS credit. The absence of this adaptation can result in an increase in the effective tax burden, which requires the controller’s office, in conjunction with the purchasing department, to establish a fiscal compliance checklist to be required from strategic suppliers before contract renewal, mitigating the risk of credit loss identified by Nascimento and De Morais (2024).

The second category, “Impact on ‘split payment’ and cash flow”, was mentioned by two respondents as a source of relevant impact on companies’ cash flow. One respondent indicated the need to “map suppliers to certify whether they are complying with the requirements and determinations of the tax reform, to avoid cash impacts with the implementation of ‘split payment’.” In practice, the “split payment” mechanism can generate a cash mismatch when the amount withheld in the transaction exceeds the available tax credit for offsetting in that period, temporarily reducing the company’s working capital.

These results are convergent with the analysis by Lima (2024), who identified risks of relevant financial impact for service companies in the transition to the new tax model, especially due to the limitation of credit utilization on the sector’s main cost items. The “split payment” dimension, however, had not been identified as a specific concern in the reviewed studies, constituting a contribution of the present work. As a solution, it is recommended that the controller’s office anticipate this effect through cash flow projections segregated by withheld tax, allowing for negotiation of payment terms with suppliers compatible with the new liquidity pace, ensuring the organization’s financial health during the transition.

Challenges in controlling in the adaptation process

The fourth block investigated the main challenges faced by the controlling area in the process of adapting to the new tax model, including the perceived impact on internal processes and the current stage of companies’ adaptation. The respondents’ perception of the impact of tax changes on the controlling area was predominantly that they “generate relevant revisions in processes and controls”. This convergence in responses is significant, as no respondent indicated an absence of impact or need for revision.

The perception that the Tax Reform will require relevant revisions in processes and controls was practically unanimous among the target group respondents, evidencing the level of impact perceived by professionals directly working in technology companies. The result from the respondent outside the target group who indicated “few revisions will be necessary” is consistent with the profile of companies in other sectors, for which the cost structure based on physical inputs allows for greater utilization of credits in the new model, reducing the extent of necessary revisions in internal calculation processes.

Content analysis of the open-ended responses allowed for the identification of four categories of operational challenges for the controller’s office. The first category, “ERP system parameterization,” was the most frequently mentioned challenge, appearing in seven out of fifteen responses. Respondents indicated the need for “review of the ‘ERP’ for IBS/CBS calculation,” “adjustments in ‘ERP’ parameterization and fiscal verification processes,” and “adaptation of Financial Statements.” This data is consistent with the understanding of Da Silva et al. (2023), that the controller’s office needs to act as an integrator of systems and information in the process of regulatory adaptation.

The second category, “Review of criteria for calculation and validation of credits”, highlighted the need for a review of credit controls, reconciliation flows, and tax reconciliations as a condition for the correct utilization of tax credits in the new model. One respondent detailed that “reviews of the criteria for calculation and validation of credits, tax planning, control and reconciliation processes, as well as adjustments to systems and management reports” will be necessary. This complexity demands a profound reevaluation of internal procedures to ensure compliance and tax optimization.

The third category, “Team technical training”, was mentioned by three respondents as a need for specific training on the new rules for credit appropriation. This training is fundamental for the controlling area to operate with quality in the new tax environment. One respondent pointed out that “the lack of technical knowledge will make it impossible for the controlling department to have clarity on the impact on the calculation”, evidencing the risk of operational inconsistencies during the transition period and the urgent need to invest in the professional development of the teams.

The fourth category, “Integration between areas”, was mentioned by four respondents, who highlighted the need for greater integration between the areas of controlling, tax, accounting, purchasing, accounts payable, and accounts receivable. One of them stated that “finance, purchasing, accounting, sales, accounts payable, accounts receivable, etc. will have to work more integrated”, suggesting that the challenges of the Tax Reform transcend the technical sphere of controlling and require a broader and more coordinated organizational response for a successful transition.

The current stage of companies’ adaptation to the new tax model revealed that most of the represented companies are in an initial stage of adaptation, with specific actions such as preliminary diagnostics, impact mapping, scenario simulations, and contract review. Only two respondents indicated complete adaptation, and in these cases, the mentioned actions predominantly referred to the adjustment of tax systems and documents, without a strategic review of controlling processes. This initial stage of adaptation represents an operational risk that tends to worsen as the transition calendar advances, as from 2026, the system already foresees the initial validity of IBS and CBS at reduced rates for testing purposes, and the extinction of PIS and COFINS is scheduled for 2027, as stipulated in LC No. 214/2025 (Brazil, 2025).

Dos Santos and De Oliveira Jurubeba (2025) identified a similar pattern in companies under the Simples Nacional, attributing the delay to the complexity of transition rules and the absence of complementary regulation in several areas, which generates legal uncertainty and hinders planning. In this context, it is recommended that the controlling department structure a tax transition plan with defined stages and deadlines aligned with the legal schedule, prioritizing the parameterization of ERP systems for the new calculation structure, the review of credit classification criteria, the technical training of teams, and the integration between the tax, accounting, and financial areas. These actions are fundamental to ensure compliance and operational continuity during the coexistence period of the two tax systems, suggesting that this pattern of incipient adaptation is reproduced among technology companies under different tax systems, requiring continuous and proactive attention.

Strategic Role of the Controller

The fifth and final block investigated the role of controlling in supporting strategic decision-making of companies in the face of tax changes, as well as the respondents’ perception of the impact of the Tax Reform on the strategic relevance of the area. The frequency with which controlling information is used to support strategic decision-making was indicated as “always” or “frequently” by 67% of the total respondents. This data indicates that, in the majority’s perception, controlling already plays a relevant role in supporting strategic decision-making, even before the full implementation of the Tax Reform. Only one respondent indicated that controlling information is never used for this purpose, which demonstrates the consolidation of the controlling function in the corporate environment.

The analysis of open-ended responses allowed for the identification of the main decision categories supported by the controlling department. The first category, “Pricing and margin analysis”, was the most frequently mentioned, appearing in nine out of fourteen valid responses. The formation of prices and the analysis of profitability by product or service are crucial decisions that the Tax Reform intensifies, as changes in the effective tax burden and usable credits directly impact margins and require a review of current pricing models. The controlling department, therefore, becomes essential to guide these strategic decisions.

The second category, “Tax planning and load projections”, highlighted the use of controlling information for tax load projections, evaluation of financial impacts of the Reform, and definition of tax planning scenarios as decisions recurrently supported by the area. The ability to project scenarios and anticipate the fiscal effects of changes is a differential that controlling offers for the company’s strategic management.

The third category, “Decisions on hiring structure”, was mentioned by three respondents, who indicated that controlling information is used to support decisions on hiring models, such as internalization versus outsourcing, and CLT versus PJ hiring. This topic is directly related to the limitation of credits on labor costs, discussed in the previous sections, and highlights the importance of controlling in optimizing the cost structure and legal compliance.

The perception that the Tax Reform tends to broaden the strategic relevance of controlling is practically consensual among respondents, with 87% agreeing totally or partially with this statement, and no respondent disagreeing. The justifications presented in the open-ended responses revealed three central arguments. The first category, “Increased complexity of calculation”, argued that the greater complexity introduced by the new model requires more sophisticated and integrated analyses from controlling between costs, taxes, and results. One respondent summarized this perspective by stating that “the Tax Reform increases the complexity of calculation, control, and utilization of credits, requiring more integrated analyses between costs, taxes, and results.”

The second category, “Controller’s Prominence in the Transition Strategy,” highlighted that the controller’s office is taking a leading role in the tax transition process, driving adaptation fronts that were previously handled exclusively by the tax department. A respondent with over twelve years of experience stated that “many pricing decisions, for example, which was something totally strategic and made by other leaders, will now have fundamental direction coming from the Controller’s Office.” This change in role reinforces the centrality of the controller’s office in strategic management.

The third category, “Impact on margins and need for continuous analysis,” emphasized that the reform “not only impacts the company’s fiscal area but also leads the controlling function to have an even more strategic vision, especially in technology companies, where the cost structure makes the impact more sensitive.” These results are in line with the argument of Araújo and Carmo (2022), for whom the controlling function, by concentrating the organization’s economic and financial information, occupies a central position in supporting strategic decisions in scenarios of normative instability. The respondents’ perception that the Tax Reform expands this protagonism confirms this theoretical perspective and contributes to the literature by demonstrating, through primary data, that professionals in the sector consistently recognize this transformation.

In summary, the results indicate that controllers in the technology sector perceive the Tax Reform as a phenomenon of relevant and multifunctional impact, demanding the intensification and reconfiguration of activities already inherent to the area. This is manifested both operationally, with the need for system parameterization, review of calculation criteria, team training, and integration between areas, and strategically, strengthening the role of controllership in pricing decisions, tax planning, and contracting structure. These findings align with the gap identified in the literature review, as studies such as those by Buzatto and Cavalcante (2022), Macedo and Monteiro (2024), and Lima (2024) predominantly focus on fiscal, redistributive, and regulatory aspects of the reform, without delving into the managerial and operational implications of tax changes within organizations. The comparison between the findings of this study and the predominantly quantitative, normative, or documentary results of these works should be understood as a convergence of meaning, not as mutual statistical validation, given the difference in methodological design between the research, but it reinforces the understanding that the reform requires a profound and strategic adaptation of companies.

4. Conclusion

The present study aimed to describe the main challenges perceived by controllers in technology companies in adapting to the new model of non-cumulativeness and calculation of tax credits, resulting from the Brazilian Tax Reform. It was found that the Reform is widely perceived as an event of significant and multifunctional impact, requiring substantial revisions in Enterprise Resource Planning (ERP) systems, credit calculation criteria, team training, and interdepartmental integration. The limitation of credit utilization on labor costs emerged as a specific structural challenge for the technology sector, whose cost structure is human capital-intensive. It was observed that this restriction, combined with the potential increase in the nominal rate of the Tax on Goods and Services (IBS) and the Social Contribution on Goods and Services (CBS), may result in an increase in the effective tax burden, even with the expansion of the right to credit on digital services. Additionally, it was identified that the “split payment” mechanism represents a relevant concern for companies’ cash flow, and that the controller’s office assumes a strengthened strategic role in pricing, tax planning, and contracting structure decisions.

The main contribution of this study lies in the identification of managerial and operational dimensions of the Tax Reform that have been little explored in the literature, such as the impact of “split payment” on cash flow and the incentive for “pejotization” as a tax strategy, demonstrating that fiscal changes transcend the normative sphere and reach strategic decisions regarding human resources and organizational structure. However, the research has limitations, notably the reduced number of respondents from the target group, which restricts the generalization of findings to the universe of technology companies. Furthermore, data collection occurred at a time of normative transition, with Complementary Law No. 214/2025 recently published and full implementation planned by 2033, which may have influenced respondents’ perceptions of impacts still in the process of being understood. For future studies, it is recommended to expand the sample, compare between technology subsectors, and conduct longitudinal monitoring of perceptions, as well as incorporate documentary analysis of financial statements to measure the impacts on companies’ effective tax burden and margins.

Bibliographic References

APPY, Bernard. Por que o sistema tributário brasileiro precisa ser reformado. Interesse Nacional, v. 8, n. 31, p. 65-81, 2015.

ARAÚJO, Hedilaine Campos; CARMO, William Júnio. Controladoria: a busca da eficácia empresarial. Altus Ciência, v. 15, n. 15, p. 239-257, 2022.

BARDIN, Laurence. Análise de Conteúdo. São Paulo: Edições 70, 2011.

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BRASIL. Lei Complementar n° 214, de 16 de janeiro de 2025. Institui o Imposto sobre Bens e Serviços (IBS), a Contribuição Social sobre Bens e Serviços (CBS) e o Imposto Seletivo (IS); cria o Comitê Gestor do IBS e altera a legislação tributária. Disponível em: https://www.planalto.gov.br/ccivil_03/leis/lcp/lcp214.htm

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