How Bill 182/2025 could increase taxes and generate a tax tsunami in the solar energy sector
Higher taxes and loss of benefits: Bill 182/2025 raises an alert about a tax tsunami in the solar energy sector. Understand the impacts.
The solar energy Brazil is facing its most critical moment since its creation. The federal government has decided to move forward with the PLP 182/2025, a proposal that reignites the ghost of Provisional Measure 232 of 2004 and inaugurates what business leaders are already calling “tax tsunami”.
The measure, which is being processed in Congress in November 2025, promises to raise tributesredesign business models and put particular pressure on distributed generation companies and storage power.
The decision stems from the government’s pursuit of increased revenue starting in 2026, when the fiscal target and the implementation of the Tax Reform intersect, creating a perfect storm scenario.
PLP 182/2025: Why is it returning now and who will be most affected?
O PLP 182/2025 This is the government’s direct response to the difficulty in meeting the primary surplus target of 0,25% of GDP in 2026.
With tax expenditures that jumped from R$ 34 billion in 2003 to R$ 564 billion in 2024, Brasília is aiming for a robust adjustment.
The problem is the target: strategic sectors, such as… solar energy, which already operate under strong competitive and regulatory pressure.
The text proposes two central movements that rekindle old fears:
1. 10% increase in the tax base for Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL). for companies under the Presumed Profit tax regime that have annual revenues exceeding R$ 1,2 million;
2. A 10% across-the-board cut in federal tax benefits., affecting PIS/Cofins, IPI and state incentives.
The official estimate is to raise R$ 19,76 billion in 2026, but experts warn of a serious side effect: loss of competitiveness, litigation, and possible business closures in the solar market.
Two tsunamis collide: Bill 182/2025 and Tax Reform raise the tax burden in an unprecedented way.
In addition to the direct increase in tributesThe sector is reacting because PLP 182/2025 will not come alone.
It will come into effect around the same time that the Tax Reform introduces the CBS and the IBS. And that’s when… tax tsunami It gains strength.
According to the reference text:
“Solar equipment, previously exempt from ICMS (a Brazilian state sales tax) in many states, will now be taxed at 28% (IBS + CBS). Even with the 70% reduction foreseen in the law, the effective tax burden rises to 9%.”
Today, the tax rate is 3,65%. That is, an increase of 164% in practice.
Furthermore, the equipment leasing model — dominant in distributed generation — will now be fully taxed, something that did not occur before, neither by ICMS nor by ISS.
Distributed generation becomes the weakest link.
Distributed generation is the basis for the expansion of solar energy In Brazil, this ends up being the most affected aspect of the proposal. Among the direct impacts foreseen:
Elimination of incentives in shared generation;
Limitation of benefits for local self-consumption up to 1 MW;
risk of losing ICMS exemption due to the end of PIS/Cofins in 2027;
rendering old contracts unviable and necessitating the restructuring of business models.
In simple terms: what was already complex will become even more expensive and bureaucratic.
Storage emerges as the only good news.
Amid the turbulent scenario, only the segment of storage The energy sector (BESS) presents some advantages. With the elimination of the IPI tax in 2027, this market will have more stable taxation under the IBS and CBS tax regimes.
The import tax on solar equipment was also reduced from 25% to 9,6%, which helps, but does not offset the increase in domestic taxes.
Business leaders are still unprepared — and time is running out.
The sector is experiencing a worrying state of neglect. According to the source text:
“Few have reviewed contracts in light of LC 214/2025; even fewer have adapted billing systems to the DERE; tax planning? Almost no one has done it.”
The final warning is straightforward: strategic windows of opportunity close at the end of December 2025.
Urgent actions to survive the tax tsunami
To avoid the worst, experts recommend:
Register lease agreements by 12/31/2025.
Migrate to the model BTS (Build to Suit).
Review all current contracts.
Adapting systems to WAIST.
Engage in aggressive tax planning.
Diversify to storage.
Closely monitor the progress of PLP 182/2025 and to act politically.
The combination of PLP 182/2025, Tax Reform, CBS, and IBS could cause impacts that go beyond the increase in tributes.
They can redesign the entire market of solar energy and to curb one of the most competitive and dynamic sectors in the country.
The central question, as the source text points out, is simple:
“The tsunami is coming. The question is: will you be prepared when it arrives?”