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Brazil Starts Test Year for Dual VAT, Forcing Immediate Invoice and Systems Changes

Real transactions begin under the dual VAT, shifting compliance risk and data demands onto companies.

Overview

  • CBS and IBS launch in transition with pilot rates of 0.9% and 0.1% that are offset against PIS/Cofins, keeping the effective 2026 burden unchanged.
  • Companies must add CBS/IBS fields and correct classifications on electronic invoices or risk rejection, incorrect payments, and potential operational stoppages.
  • The Receita Federal and the IBS Management Committee postponed automatic fines for missing CBS/IBS data until the first day of the fourth month after regulations are published.
  • Under assisted assessment, buyers can lose tax credits if suppliers fail to pay, and new payment-linked records require tight ERP integration to validate each transaction.
  • Split payment will route tax directly to the government from 2027, prompting 2026 cash‑flow planning, while many small firms still rely on ERP upgrades as Receita and Serpro expand infrastructure with investments exceeding R$1 billion.