Tax Reform: Review of corporate purpose and registered CNAEs

Domingues e Pinho Contadores recommends that companies review their corporate purpose and registered CNAEs (National Classification of Economic Activities) before the end of 2026, due to the changes introduced by the Consumption Tax Reform.

Complementary Law No. 214/2025, as amended by Complementary Law No. 227/2026, established the IBS (Goods and Services Tax) and the CBS (Contribution on Goods and Services) and set forth, in addition to the general tax regime, specific and differentiated regimes for certain activities and transactions. The legislation also provides for different tax treatments and obligations related to the reporting of information and the issuance of tax documents.

In this new landscape, the accurate identification of economic activities becomes even more important. Tax classifications that do not reflect the company’s actual operations can lead to unnecessary analyses, parameterizations, and tax audits and, depending on the activity, to additional ancillary obligations, thereby increasing compliance costs and exposure to tax risks.

Therefore, we recommend that each company assess:

• whether the activities currently listed in the corporate purpose are still relevant; and
• whether the primary and secondary CNAE codes correspond to the activities actually carried out;
• whether there are registered activities that are not being carried out and for which there is no concrete expectation of commencement in the short term.

➡️ Where applicable, we recommend removing activities that are not actually carried out or that are not expected to be carried out, retaining in the corporate purpose and registrations only those that are consistent with the company’s current operations and short-term plans.

We suggest that this review and any necessary adjustments be carried out during the 2026 fiscal year, as a preventive measure ahead of the start of the new phases of the Tax Reform’s implementation.

The assessment should be conducted internally by the company and, where necessary, in coordination with its legal and corporate affairs department.

Support for Tax Reform Compliance

The Tax Reform requires companies to assess and adapt different aspects of their routines throughout the transition period. To identify the necessary measures and plan the next steps, rely on the expertise of Domingues e Pinho Contadores specialists.

Contact our advisory team: dpc@dpc.com.br.