The RFB and the Goods and Services Tax Management Committee have issued guidance on the new CBS and IBS taxes, effective 1 January 2026, outlining electronic invoicing, reporting obligations, and a 2026 trial-year exemption from payment for compliant taxpayers.
Brazil’s tax authority, the Federal Revenue Service (RFB) and the Goods and Services Tax Management Committee (CGIBS) have released guidance on the upcoming Contribution on Goods and Services (CBS) and Goods and Services Tax (IBS) on 2 December 2025 under Complementary Law No. 214/2025 (Consumption Tax Reform).
This latest guidance on Goods and Services (CBS) and Goods and Services Tax (IBS) goes into effect on 1 January 2026.
Key points include:
1. Obligations Starting in 2026
From January 1, 2026, taxpayers will be required to:
- Issue electronic tax documents highlighting CBS and IBS, itemised by transaction, in accordance with the rules and layouts defined in specific Technical Notes for each document.
- Declarations for specific regimes (DeRE) and digital platform reports must be submitted as soon as they are available.
- Individuals subject to CBS and IBS must register with CNPJ from July 2026, solely for tax reporting purposes.
2. Ancillary Obligations
From 1 January 2026, the following electronic tax documents must be issued, highlighting CBS and IBS, and will be authorised according to specific Technical Notes:
- Electronic Invoice – NF-e
- Electronic Consumer Invoice – NFC-e
- Electronic Transport Knowledge – CT-e
- Electronic Transport Knowledge – Other Services – CT-e OS
- Electronic Service Invoice – NFS-e
- Electronic Service Invoice for Road Use – NFS-e Via
- Electronic Invoice for Communication Services – NFCom
- Electronic Invoice for Electric Energy – NF3e
- Electronic Travel Ticket – BP-e
- Electronic Travel Ticket – Metropolitan Transport – BP-e TM
Taxpayers unable to issue documents due to federal or state limitations will not be penalised.
3. Layouts Under Development
- NF-e Gas (Gas Invoice) will have layouts and effective dates defined in a Technical Note or Joint Act of CGIBS and Federal Revenue.
- Declarations of Specific Regimes – DeRE, under development for Financial Institutions, Health Care Plans, Prognosis Contests, Consortium Administration, Insurance, and Pensions, will have layouts and effective dates defined in a Technical Note or Joint Act of CGIBS and Federal Revenue.
- Other taxable events that currently do not require issuing tax documents but will need to be included in electronic tax documents highlighting CBS and IBS, will have layouts and effective dates defined in a Technical Note or Joint Act of CGIBS and Federal Revenue.
4. Digital Platforms
Digital platforms will have their reporting rules, including formats and start dates, set by a Technical Note or joint act from CGIBS and the Federal Revenue Service.
5. Exemption from Payment in 2026 Upon Compliance with Ancillary Obligations
Since 2026 is a trial year for CBS and IBS, taxpayers who issue tax documents or specific regime declarations in accordance with current rules and technical notes will be exempt from paying CBS and IBS. Likewise, taxpayers without defined ancillary obligations will also be exempt from these taxes.
6. Compensation Funds for Tax Benefits
Starting January 2026, holders of ICMS benefits can apply for eligibility for future compensation rights under Article 384 of Complementary Law No. 214/2025 through e-CAC, using an electronic form available in SISEN, as established by a normative act.
