Brazil’s government has released an updated version of Technical Note NT 2024.002 on 6 December 2024.

This updated version introduces new validation rules to calculate the monthly amounts due for the recently implemented indirect taxes – CBS and IBS.

This follows after the government’s submission of regulations to Congress regarding implementing a new dual value-added tax (VAT) system as part of its tax reform bill.

Brazil’s tax reform proposes two harmonised (federal and state) taxes:

  • IBS, which replaces state VAT (ICMS), and municipal service tax (ISS);
  • CBS, which replaces federal PIS/COFINS contributions.

The update introduces a new tax code (CST in Portuguese) for CBS, IBS, and IS (selective tax).

While CST codes are known to Brazilian taxpayers under the current tax system (e.g., PIS, COFINS, IPI, ICMS), the new values for CBS, IBS, and IS offer more details regarding how each item on the e-invoice will be taxed.

There has been no changes to the timeline for implementing the amendments, which are as follows:

  • From 1 September 2025 to 30 October 2025: The updates introduced in NT 2024.002 will be accessible in the testing environment of the e-invoice portal.
  • From 31 October 2025 to 31 December 2025: The changes will go live in the production environment; however, taxpayers are not required to complete the new CBS and IBS fields until they take effect on 1 January 2026.
  • From 1 January 2026: New fields and validation rules will be fully implemented.