The use of 2026 as a simulation year is already prompting companies to reassess operational decisions that were previously shaped by the current tax framework. Logistics is the most visible dimension of this shift. Structures originally designed to capture tax incentives are being reconsidered in a system that aims to reduce such distortions. Companies that have located operations in specific states due to tax incentives are now evaluating potential reorganization. “The goal is to make decisions based more on economic factors than tax implications,” explains Rafael Amorim, partner in the Tax division at Vieira Rezende. This shift implies not only potential relocation but also a broader reassessment of operational efficiency.

The impact, however, extends beyond logistics. The reform introduces a variable that directly affects companies’ financial structure: cash flow dynamics across the supply chain. The timing of input tax credits, combined with taxation at the point of output, shifts attention to the gap between these events. “There is a critical timing issue between recognizing tax credits and paying the corresponding tax, which directly affects companies’ cash flow,” he explains. As a result, structures that appear efficient from a margin perspective may prove more demanding in terms of working capital, requiring closer integration between operational and financial planning.

A third area affected is the review of commercial relationships structured under the current system. Contracts with suppliers and customers are being revisited to reflect the anticipated effects of the reform, often before those effects are fully measurable. “Companies are reviewing contractual arrangements to adjust clauses and anticipate the impact of the reform,” Amorim notes. This process may involve cost reallocation, pricing adjustments, and, in some cases, the economic rebalancing of contractual relationships, with effects cascading throughout the supply chain.

For foreign investors, these variables are becoming central to asset valuation and market-entry decisions. In M&A transactions, reliance solely on historical performance becomes less relevant in a context of structural change. “A company’s valuation today must incorporate how the reform will affect future cash flows. This fundamentally changes the analytical framework,” Amorim emphasizes. In this context, a company’s ability to adapt to the new tax system becomes an integral component of its overall value.

Explore the full edition here.