Constitutional Amendment 132/2023
The constitutional framework, destination-based taxation and transition rules.
Constitutional amendment • December 20, 2023Read at sourceA Today Brazil guide
Brazil’s tax reform, connected.
What changes for consumption taxes, when it takes effect and how split payment changes settlement. A visual guide with official sources alongside each explanation.
Editorial review:
01CBS
Federal level
Replaces PIS/Cofins from 2027.
02IBS
States and municipalities
Gradually replaces ICMS/ISS from 2029 to 2033.
03Split
At payment settlement
Separates the tax portion from the business’s proceeds.
Before and after
What changes, side by side.
The transition is gradual. This compares the previous structure with the reform’s design; it does not imply that every rule is already operational.
In practicePrevious structureReform design
Consumption taxes
Previous structure
Federal PIS/Cofins, state ICMS and municipal ISS, with different rules.
Reform design
Federal CBS and IBS shared by states and municipalities, replacing the old taxes on the transition schedule.
Official source: Presidência da RepúblicaRevenue destination
Previous structure
Origin and destination rules vary across taxes and transactions.
Reform design
IBS follows consumption at destination, with a separate transition for revenue distribution among governments.
Official source: Presidência da RepúblicaInput credits
Previous structure
Eligibility and restrictions depend on each tax and regime.
Reform design
Under the regular regime, IBS/CBS credits depend on fiscal documentation and discharge of the related tax debt, subject to statutory exceptions.
Official source: Câmara dos DeputadosReceipts and cash flow
Previous structure
In a flow without withholding, the business receives payment and remits tax later.
Reform design
Split payment segregates tax at settlement. The cash effect depends on credits, the regime and the transaction.
Official source: Presidência da RepúblicaSimples Nacional
Previous structure
A dedicated regime for small businesses.
Reform design
It remains in place. Businesses may elect the regular IBS/CBS regime, subject to its credit and election rules.
Official source: Câmara dos DeputadosSelective Tax and IPI
Previous structure
IPI is part of federal taxation of manufactured products.
Reform design
Selective Tax is scheduled for 2027. IPI rates fall to zero, with exceptions related to the Manaus Free Trade Zone.
Official source: Receita FederalSplit payment
Follow the money.
Split payment collects IBS/CBS at financial settlement. Change the values and compare when the tax portion leaves the business’s cash flow.
Cash-flow example • hypothetical values
Illustration, not a tax or savings calculation. You choose the amounts; they do not represent a statutory rate. No credits, withholding, installments, returns or special regimes are modeled. The stated tax portion is assumed to be fully segregated.
At financial settlement
Customer paysR$1,000.00
Business receivesR$800.00
Tax authority receivesR$200.00
Tax segregated at settlementR$200.00
After remitting the same taxR$800.00
Portion that no longer passes through the businessR$200.00
Final proceeds are equal in both scenarios in this example. The difference is the timing and route of remittance; this may require reviewing working capital.
Legal basis: LC 214, arts. 31–35; CBS regulation, arts. 28–33. Official source: Câmara dos Deputados · Official source: Presidência da República
Timeline
A transition in stages.
Select a milestone to see what is planned. The tax transition schedule is distinct from the split payment activation schedule.
2026
Regulation and adaptation
LC 227 and the CBS regulation detail implementation. Nominal test-year rates are 0.9% CBS and 0.1% IBS, with payment waived for those meeting ancillary obligations under the law. Split payment testing follows its own schedule.
Official source: Receita FederalWhat should you look at?
Planning points selected by Today Brazil from the rules. Effective tax burden depends on the transaction and applicable regime.
Invoices, receipts and credits must connect.
Linking fiscal documents with payments is central to split payment flows.
Official source: Presidência da República- Review ERP and payment system integration.
- Reconcile segregated amounts and remaining liabilities.
- Project cash without treating the tax portion as freely available funds.
Official texts
Go straight to the source.
Selected laws, guidance and technical documents. Links open the complete text on the responsible authority’s website; summaries are by Today Brazil. This is not an exhaustive register of every reform act.
11 references
Complementary Law 214/2025 — updated
IBS, CBS and Selective Tax. Split payment in arts. 31–35, Simples in art. 41 and credits in arts. 47–48. Consolidated Chamber of Deputies PDF.
Law • includes subsequent amendmentsRead at sourceComplementary Law 227/2026
Establishes CGIBS and amends LC 214. Covers governance, procedures and adjustments to split payment.
Law • January 13, 2026Read at sourceDecree 12,955/2026 — CBS regulation
Details CBS implementation. Article 33 provides for gradual split payment rollout through joint acts by the Revenue Service and CGIBS.
Regulation • consolidated textRead at sourceIBS regulation and CGIBS resolutions
Official repository of Resolution 6/2026, which regulates IBS, and subsequent acts. Read amendments alongside the original regulation.
Regulation • versions and amendments at sourceRead at sourceUnderstanding the consumption tax reform
Revenue Service overview of the taxes, test year and transition schedule.
Guidance • page updated October 16, 2026Read at sourceFiscal documents: guidance and schedules
Check the timetable for each document. Layout publication and mandatory adoption are different milestones.
Guidance • document-specific schedulesRead at sourceSplit payment: testing notice
September 30 announcement of integration tests planned for October 15, 2026, in a controlled environment without real transactions.
Notice • September 30, 2026Read at sourceSimples Nacional: adapting to the reform
CGSN updates and guidance on the options for assessing IBS and CBS.
Guidance • August 2026Read at sourceSplit payment: CGIBS technical library
Integration, operations, timing, security, networks, authorization and OpenAPI. Current and previous versions are identified by the authority.
Technical documentation • versions at sourceRead at sourceOfficial tax calculator: pilot FAQ
Revenue Service FAQ from the calculator pilot. A technical reference on how it works, not an announcement of current availability.
Pilot manual • FAQ version 1.4 (PDF)Read at sourceThree questions that matter.
Is split payment a new tax on Pix?
No. It is a mechanism for collecting IBS/CBS on taxable transactions through covered payment arrangements. Using Pix does not, by itself, make every transfer taxable.
Official source: Presidência da RepúblicaIs there one rate for everyone?
No single percentage describes every business’s tax burden. The law provides reductions, regimes and credits. The chart values only illustrate settlement.
Official source: Câmara dos DeputadosMust all split payment start in January 2027?
The regulation provides for stages defined by joint acts. CBS starting does not establish universal split payment activation; follow official acts and technical schedules.
Official source: Presidência da RepúblicaThe reform in recent editions.
Related content from the portal’s published editions, with dates and links to the original sources.
Dual IVA tax reform faces institutional friction between federal and local authorities
Brazil's tax reform harmonizes rules for the federal CBS and subnational IBS, but leaves administrative enforcement split between the Receita Federal and the IBS Management Committee, CGIBS.
Tax reform risks weakening regional demand for logistics warehouses
Bresco Logística (BRCO11) manager Rafael Fonseca states that ending state ICMS tax incentives will shift industrial warehouse demand away from subsidized interior regions toward major urban consumption hubs.
Tax shift forces Brazilian automakers to restructure investment strategies
Tax specialists consulted by JOTA report that transitioning state ICMS benefits to destination-based CBS and IBS consumption taxes will force automakers to prioritize supply chain efficiency over regional development subsidies.
STF Overturns Tax Reform Limits on Car Exemptions for Disabled Buyers
The STF, Brazil's Supreme Federal Court, unanimously struck down restrictions under Complementary Law 214/2025 that narrowed 100% tax discounts on IBS and CBS taxes for car purchases by disabled individuals and people with autism. The ruling in ADIs 7,779 and 7,790 established that lawmakers exceeded their regulatory powers by imposing severity tiers not present in Constitutional Amendment 132/2023.
Debate Over Suspending Tax Reform Sparks Calls to Restore Single IBS Model
Proposals to suspend or revoke tax reform regulations for up to a year clash with technical calls to return to the original PEC 45/2019 framework. Critics argue that postponing implementation prolongs uncertainty under ICMS, ISS and PIS/Cofins without resolving administrative duplication between the federal CBS tax and subnational IBS tax, whereas returning to a unified IBS depends on shared governance that Congress has yet to resolve.
Energy regulator technical body proposes transition path for tax reform implementation
Technical staff at ANEEL, Brazil's electricity regulatory agency, recommended a 10-day public consultation on Oct 13 to guide the replacement of PIS and Cofins taxes by the CBS contribution on Jan 1, 2027. The proposal keeps current Regulatory Remuneration Base calculations intact for power distributors and transmitters until the 2027/2028 tariff cycle.
The next step starts at the source.
Selection and explanation: Today Brazil. References checked on this date; subsequent rules may change the schedule.