Fiscal subject related
Brazil has published new implementing rules for its indirect tax reform, introducing a new dual VAT system made up of two taxes: Federal VAT (CBS) and State VAT (IBS).
The new rules are set out in Decree No. 12.955/2026 for Federal VAT (CBS) and CGIBS Resolution No. 6/2026 for State VAT (IBS).
The reform is especially important for foreign suppliers, digital platforms, and companies selling digital services, remote services, intangibles, or goods into Brazil.
One of the biggest changes is that foreign digital platforms may become responsible for collecting and reporting the Federal VAT (CBS) and State VAT (IBS) on transactions they intermediate. This means that platforms can no longer act only as intermediaries. In many cases, they will also have tax compliance responsibilities.
The new rules also expand Brazil’s tax reach. Remote services, digital supplies, and intangible goods may fall under the Brazilian tax system when the customer is located in Brazil or when the service is consumed in Brazil.
Operational compliance will begin on August 1, 2026. From this date, businesses must be ready for registration and electronic fiscal-document obligations. However, 2026 will remain a transition year. CBS and IBS calculations during 2026 will be informational only, provided that companies comply with registration and electronic document requirements.
Financial tax exposure is expected to begin from 2027, when the new regime moves into broader implementation.
The reform also relies heavily on Brazil’s electronic fiscal-document system. Existing documents such as e-Invoice (NF-e), e-Receipt (NFC-e), electronic service invoice (NFS-e), and electronic transport document (CT-e) will be adapted, and new documents will also be introduced. In addition, Brazil plans to use a split-payment mechanism, where payment service providers separate and remit CBS and IBS during payment settlement.
Foreign digital platforms that are liable for CBS or IBS must register in Brazil through the CNPJ tax identification system before starting their activities. There is no general registration threshold for foreign platforms.
If a foreign supplier or platform is not registered, CBS and IBS may be collected at reference rates by the institution responsible for the foreign-exchange remittance.
Several important details are still pending. Further guidance is expected on platform reporting, electronic document layouts, registration procedures, split-payment mechanics, consolidated fiscal documents, and compliance programmes.
For businesses, the key message is clear: companies selling into Brazil or operating digital platforms with Brazilian customers should start preparing now. They will need to check whether their systems can identify Brazilian customers, determine customer status, report underlying sellers, issue the required fiscal documents, and support future split-payment requirements.
The immediate priority is to be operationally ready by August 1, 2026, while continuing to monitor further technical guidance expected throughout 2026.
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