Evolua Consultoria

A seven-year reform, and every year asks your company for a different decision.

The Tax Reform Committee stays with the company through the whole IBS and CBS transition, from the first impact assessment to running under the new system.

Brazil’s tax reform has left the debate and entered the calendar. Constitutional Amendment 132/2023 and Complementary Law 214/2025 replace five consumption taxes with three, in steps running to 2033, with regulation still being written along the way. This is not a change of acronyms: the tax base changes, credits change, invoicing changes, and so does who gains and who loses at each link of the chain.

The transition ruler

  1. 2026

    Test year

    CBS at 0.9% and IBS at 0.1%, offsettable against PIS and COFINS. The cost is low and the workload is high: the new taxes already have to be shown on the invoice.

    You are here

  2. 2027

    CBS in full

    CBS comes in at full rate and PIS and COFINS are extinguished. IPI drops to zero outside the Manaus Free Trade Zone, and the Selective Tax starts to apply.

  3. 2029

    ICMS and ISS phase-out

    IBS rises while ICMS and ISS fall in annual steps through 2032. For those four years the company files under both systems at once.

  4. 2033

    The new system, whole

    ICMS and ISS are extinguished. IBS, CBS and the Selective Tax remain. And the decisions taken along the way have already turned into cost or advantage.

What goes and what arrives

Current system

New system

PIS and COFINS

CBS

ICMS and ISS

IBS

IPI, zeroed outside the Free Trade Zone

Selective Tax

Length of the transition
2026 → 2033
Taxes extinguished
PIS · COFINS · ICMS · ISS
New taxes
IBS · CBS · IS
Years filing under both systems
2029 → 2032

What really changes sits under that table. IBS and CBS are broadly non-cumulative: the buyer takes credit for what was paid upstream, which rearranges each supplier’s standing along the chain. Services, which today pay ISS at a low rate with little input to credit, feel it one way; industry and retail, which already live on credits, feel it another.

The Tax Reform Committee

The transition is not a project with a delivery date. It is a sequence of decisions spread over seven years, with the rules still being written as it runs. That is why the Committee exists: instead of one assessment delivered and filed away, Evolua sits with the company through the whole transition, and stays afterwards, once the new system is running.

Impact assessment

What the changes do to the tax burden, to pricing and to the operation, sector by sector and product by product.

Adapting processes, systems and controls

What has to change in the ERP, in invoicing and in internal controls to meet the new requirements.

Tracking the regulation

The rules keep being written. Each new piece is read and translated into a decision for this company, not into a generic bulletin.

Decisions while there is time

Credits, pricing, contracts and corporate structure all add up differently under the new system. Each has a window in which to be revisited.

The rates will still move. What can already be known is where your operation loses and where it gains in the switch. And that changes pricing and contract decisions now.

Questions we get

Does the reform apply to companies under Simples Nacional?

Simples Nacional continues to exist, and a company under it can choose to pay IBS and CBS inside the regime or outside it. The arithmetic depends on the customer base: buyers who use credits prefer suppliers that generate full credit.

My company provides services. Will it pay more?

Services feel the switch most, because today they pay ISS at a low rate with little input to credit. The final result depends on the chain: who the company sells to and how much it buys from third parties.

Can we wait for the regulation to be finished?

The rules will keep being written throughout the transition, so waiting means never starting. What is already in force does not wait: showing the new taxes on the invoice began in 2026.

What changes in the company’s systems?

Invoicing, product and service registries, tax calculation and ancillary filings. Between 2029 and 2032 the system has to calculate under both regimes at once.

Where do we start?

With the impact assessment. Without knowing what the reform does to the margin of each product line, any pricing or structural decision is a guess.

Shall we map what the reform does to your operation?