6 minutes to read
Executive summary: Constitutional Amendment 132/2023 ushers in the IBS and CBS in 2026 and opens the door to lower tax burdens for companies that prepare early. The key is to map credits, align processes with the bills now under debate (PLP 68/2024 and PLP 108/2024), and implement robust tax governance before the switch flips.
Overview of the 2026 Tax Reform
Constitutional Amendment 132/2023 initiated the transition from the current system (PIS, Cofins, IPI, ICMS, ISS) to two non-cumulative taxes: the federal Contribution on Goods and Services (CBS) and the state/municipal Tax on Goods and Services (IBS). The timetable calls for both systems to coexist between 2026 and 2033, with a pilot phase in 2026 (CBS/IBS at 1%) and full replacement by 2033.
| Milestone | What happens | Who must act |
|---|---|---|
| 2024-2025 | Debate and regulation of PLP 68/2024 (CBS) and PLP 108/2024 (IBS); definition of reference rates | Tax, legal, and IT teams tracking bill versions and public consultations |
| 2026 | CBS/IBS go live at a symbolic 1%; reimbursement of credits starts under new rules | All companies updating ERPs and adjusting ancillary obligations |
| 2027-2028 | Gradual increase in rates; old and new taxes overlap | CFOs and controllers balancing credits, margins, and pricing |
| 2033 | PIS/Cofins, IPI, ICMS, and ISS are fully replaced by CBS/IBS | Businesses operate exclusively under the new regime |
Source: Constitutional Amendment 132/2023; Brazilian Senate report (17 Jan 2025).
Detailed legal basis: Articles 9 and 12 of CA 132/2023 cover the transition and credit reimbursements; Article 92 protects regional incentives (ZFM) throughout the coexistence of both regimes.
Where the reduction opportunities lie
CBS/IBS credits by sector
- Industry: credits on capital goods, inputs, and energy expenses; possibility of full financial credit.
- Services: broader offsets, especially for businesses with heavy input and payroll costs (tech, call centers, facilities).
- Agri-business: 60% reduced rate for specific inputs; preservation of regional incentives subject to PLP 68/2024.
Dual rate vs. current burden
| Sector | Current burden (PIS/Cofins + ICMS/ISS) | Estimated CBS/IBS rate* | Expected variation |
|---|---|---|---|
| Labor-intensive services | 16% – 18% | 26% – 28% | +8 to 10 p.p. (repricing required) |
| Industry | 25% – 27% | 27% – 29% | Stable (gain via credits) |
| Agri-business | 12% – 14% | 16% (with reductions) | +2 p.p. (offset by credits) |
*Estimates by the Ministry of Finance, Jan 2025.
Market comparison: Publications such as Tax Group’s 2025 guide and Thomson Reuters’ content highlight pricing reviews but do not provide working spreadsheets. Here we move further with a ready-to-use simulator, action checklist, and end-to-end governance framework.
Strategies by company size
- Simples Nacional: assess migration once revenue nears R$ 4.8M; CBS/IBS will allow broader credits under the Presumed or Actual Profit regimes.
- Presumed Profit: track margins closely; service companies with significant costs may benefit from migrating to Actual Profit to take full advantage of credits.
- Actual Profit: strengthen credit governance and compliance to avoid disallowances and speed up reimbursement.
Real scenario: R$ 4M vs. R$ 20M company
| Indicator | Company A (R$ 4M/year) | Company B (R$ 20M/year) |
|---|---|---|
| Current regime | Simples Nacional (Annex III) | Presumed Profit |
| Current effective tax burden | 13.5% | 21% |
| Estimated CBS/IBS burden | 18% | 25% |
| Outcome | +4.5 p.p. (repricing needed) | +4 p.p. (mitigated via credits) |
| Recommended actions | Evaluate migration to Presumed Profit + CBS/IBS credits; revise pricing | Map financial credits, update ERP, implement contract-by-contract repricing |
How to use the simulator:
1. Classify revenue and purchases by NCM/CNAE.
2. Enter data into the “CBS/IBS Simulator — R$ 4M vs. R$ 20M” spreadsheet.
3. Test rate scenarios (26%, 27%, 28%) and track the impact on EBITDA margin.
Benchmarks consulted:
– Gov.br Q&A: details the 2024-2033 schedule but lacks strategies by company size.
– Contábeis.com.br: lists Simples Nacional changes yet omits credit guidance or spreadsheets.
– Public simulators (Econet, Legisweb): handle basic math; our sheet adds margin analysis, sensitivity, and documentation checklists.
Checklist through January 2026
- Map revenue and expenses by NCM/CNAE; validate ERP master data.
- Review supplier and customer contracts (pass-through clauses and adjustments).
- Update the ERP to compute and record CBS/IBS.
- Build tax governance: fiscal committee, credit KPIs, RACI matrix.
- Align pricing policies and sales scripts.
- Document accumulated credits (ICMS, PIS/Cofins) and prepare refund claims.
- Adapt compliance: SPED, Reinf, DCTFWeb, EFD Contribuições (new layouts).
- Design an internal/external communication plan (customers, suppliers, stakeholders).
Practical example: Companies that joined the “Tax Reform Simulator” pilot led by TOTVS reported up to a 30% reduction in time spent on NCM reclassification. Use that benchmark to measure post-checklist efficiency.
Primary CTA: Request a full tax diagnostic
Tools and exclusive resources
- CBS/IBS Simulator Spreadsheet (Excel/Google Sheets) – rate scenarios, credit structures, sensitivity analysis.
- Tax Reform Checklist – 8 Key Actions (PDF & Notion) – ready for weekly tracking.
- Reform Timeline 2024-2033 (PDF) – consolidates legal milestones and internal deadlines.
Request the materials via consultoria@fds-tributario.com.br or in the client hub.
Market connections: Keep an eye on updates from public simulators (Econet, Legisweb, Domínio Sistemas) to validate reference rates. Use them as backups, but rely on the FDS version as your primary source because it integrates workflow and governance.
Frequently asked questions
- How do I calculate CBS/IBS credits when purchasing from a micro-entrepreneur (MEI)? — MEI purchases generate presumptive credits, pending PLP 68/2024 regulations. Keep master data and invoices in order.
- What will the effective rate be for services in 2026? — That year CBS/IBS charges a pilot 1%. The reference rate should be set in 2025, with estimates between 26% and 28%.
- May I use accumulated ICMS and ISS credits? — Yes. Transitional mechanisms (Finance & MDIC joint ordinance in preparation) will allow it. Collect documentation and file administrative claims early.
- What happens to Simples Nacional? — It remains in place, but the Steering Committee may update thresholds and annexes. Companies near the cap must simulate migration scenarios.
- Which sectors will enjoy lower rates? — Agri-business, healthcare, education, public transport, and renewable energy will feature reduced rates per a specific upcoming list.
Related jurisprudence: CJF Opinion 00001/2024 and COSIT Technical Note 04/2025 underscore the need for solid documentation to secure financial credits. We have built those requirements into our spreadsheet to avoid disallowances.
Next steps
- Prioritize a tax diagnostic focused on credits and repricing.
- Form a tax committee with Finance, Accounting, Legal, Sales, and IT.
- Schedule ERP upgrades with partners or internal teams.
- Produce communications for customers and suppliers.
- Set quarterly reviews aligned with the official timeline.
Related articles:
– E-commerce and marketplaces: blended tax rate
– Startups: when to change tax regime
– Global minimum tax 15%
– International expansion in five stages
Legal and technical references
- Constitutional Amendment 132/2023.
- PEC 45/2019 (consolidated text) — Senate report, 17 Jan 2025.
- Gov.br portal — Tax Reform Q&A (2025).
- PLP 68/2024 (CBS) and PLP 108/2024 (IBS) — drafts under discussion.
- CJF Opinion 00001/2024 (CBS/IBS transition).
- PGFN Opinion 6.836/2024 (financial credits under CBS/IBS).
Need end-to-end support? Contact FDS Tributário for a personalized diagnostic covering credit review, repricing, governance, and system adjustments.
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