Brazil introduced a four-month penalty-free transition and a 2026 testing year for its new IBS/CBS VAT, during which companies must report the new tax fields on e-invoices but no tax will yet be collected. The resolution also confirms which electronic invoice types will be used and which authorities manage service invoices and small-business regimes as Brazil prepares for full VAT rollout.
Brazil Grants Penalty Relief and Confirms e-Invoice Rules for New VAT System
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Brazil
Author: Ivana Picajkić
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Fiscal subject related
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581
Content accuracy validation date:
20.01.2026
Content accuracy validation time:
08:17h
Brazil’s Federal Revenue Service and the IBS Management Committee (CGIBS) have issued a joint resolution on December 22, 2025 to support businesses as they prepare for Brazil’s new VAT system (IBS and CBS).
The resolution gives companies temporary relief from penalties and clarifies which electronic invoices will be used under the new tax system.
To help companies adapt, the authorities introduced a four-month grace period once the new IBS/CBS rules are published.
During this period:
- Companies will not be fined if their invoices are missing IBS or CBS fields,
- They will also not be penalized for incomplete reporting related to IBS and CBS.
In addition, for 2026, the IBS and CBS amounts shown on invoices will be informational only. This means the numbers will be reported, but no tax will actually be collected, as long as companies meet their reporting obligations.
The resolution confirms which electronic documents will be valid under the new VAT system.
New invoice types include:
- NFAg (model 75) – water and sanitation,
- NFGas (model 76) – gas supply,
- NF-e ABI (model 77) – real estate,
- DeRE – special tax regimes.
At the same time, Brazil will continue using its existing electronic documents, including e-Invoices (NF-e), digital fiscal receipt (NFC-e), NFS-e, CT-e, BP-e, MDF-e, NF3e, NFCom and others.
The resolution also explains who manages different parts of the system:
- CGNFS-e (Management Committee of the Electronic Service Invoice) will manage electronic service invoices (NFS-e),
- CGSN (Management Committee of the Simples Nacional tax regime) will manage rules for small businesses under Simples Nacional.
It also confirms that other taxes remain unchanged and that separate rules will be issued for foreign trade.
Brazil is using 2026 as a testing and adjustment year for its new VAT system. Companies are expected to issue invoices with IBS and CBS data, but they will not be punished for mistakes during the initial rollout.
More technical changes are expected as Brazil continues to upgrade its e-invoicing and VAT systems ahead of full implementation.
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