Tax Reform: IBS Management Committee and Federal Revenue Service issue joint statement with guidelines

The Federal Revenue Service and the Goods and Services Tax Management Committee have published important guidelines on the entry into force of the CBS and IBS as of January 1, 2026. Among the guidelines for companies, we highlight:

Mandatory from 2026

From January 1, 2026, taxpayers will be required to issue electronic tax documents highlighting CBS (Contribution on Goods and Services) and IBS (Tax on Goods and Services), individualized by transaction, in accordance with the rules and layouts defined in specific Technical Notes for each document.

The statement also mentions the obligation to submit, when applicable, Specific Regime Declarations (DeRE) and tax declarations and/or documents from digital platforms. However, the start date for these obligations will be announced at a later date, once the technical documentation for these documents has been published.

Regarding DeRE, on December 12, 2025, the technical documentation was published that allows developers to begin structuring it, but we still do not have a date for the first delivery of the obligation. Access the technical documentation here.

Ancillary obligations

As of January 1, 2026, the following electronic tax documents must be issued with CBS and IBS highlighted:

• Electronic Invoice – NF-e;
• Electronic Consumer Invoice – NFC-e;
• Electronic Transport Knowledge – CT-e;
• Electronic Transport Knowledge for Other Services - CT-e OS;
• Electronic Service Invoice – NFS-e;
• Electronic Service Invoice for Road Use – NFS-e Via;
• Electronic Communication Services Invoice – NFCom;
• Electronic Electricity Invoice – NF3e;
• Electronic Ticket of Passage – BP-e; e
• Electronic Ticket Metropolitan Transportation – BP-e TM.

Exemption from payment in 2026

Taxpayers who comply with ancillary obligations will be exempt from paying taxes next year, which will be dedicated to testing the Tax Reform.

The statement also makes it clear that the exemption from payment will remain in cases where there is no defined ancillary obligation.

Tax Benefit Compensation Funds

Starting from January 1, 2026, holders of benefits related to ICMS (Tax on Circulation of Goods and Services) will be able to submit requests for procedures to qualify for future compensation rights through e-CAC, by filling out a form that will be made available at a later date.

The full text of the Joint Communication CGIBS/RFB 01/2025 can be viewed here.

It is extremely important to keep up with announcements, technical notes, and future regulations in order to remain compliant with the rules to be followed during this transition phase of the national tax system.

Specialized support

Count on DPC to analyze the impact of the Tax Reform, assist in adapting routines, and guide your company in building a tax strategy aligned with the new landscape. Contact DPC: dpc@dpc.com.br.