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Brazil Proposes One-Month Delay for First CBS Payment

The Finance Ministry will send a complementary bill to Congress to let firms pay January's CBS by estimate in February with a final adjustment in March, easing cash‑flow and operational strain during the switch to split payment.

Overview

  • On Wednesday, the Receita Federal and the Finance Ministry announced they will ask Congress to approve an optional rule letting companies estimate and pay January 2027's CBS in February and adjust the accounts in March.
  • The change would not move the CBS start date of January 1, 2027; it must be enacted by a complementary law and would apply only to 2027 unless lawmakers extend it.
  • A coalition of 75 business groups has urged a much longer delay, asking for tests through 2027 and definitive collection to begin in January 2028, while the government has rejected a full postponement.
  • The TCU set a reference CBS rate of 11.3% for 2027, a figure higher than prior ministry estimates that the Senate must review by December 15 with CAE hearings scheduled for November 17–18.
  • The proposal includes operational safeguards such as temporary flexibility in fiscal documents, the use of Recolhimento pelo Adquirente and a prefilled apuração assistida tool, and a promise not to penalize taxpayers who act in good faith during the transition.