|B2B, B2G and B2C e-invoicing is mandatory||Yes|
Brazil Electronic Invoicing and Digital Reporting Requirements
|Indirect tax control regime||CTC|
|E-Invoicing/CTC Model||CTC Clearance|
|Governing entity||Ministry of Finance, Federal Revenue Service of Brazil, Municipalities (Secretária de Finanças Municipal)|
|Infrastructure/platform||SPED for NF-e and others|
|Domestic Transactions||B2B - yes, B2C - yes, B2G - yes|
|Cross-border Transactions||Export - yes, Import - yes|
|Supplier-side requirements (AR)|
|Format(s) while sending to the platform||All electronic invoice formats are in XML but with different structures based on the e-invoice type. Here are some of the main formats: a) NF-e (Nota Fiscal Eletrônica): e-invoice for the supply of goods and certain services, 2) NFS-e (Nota Fiscal de Serviços Eletrônica): e-invoice for the supply of services subject to ISS, 3) SN NFS-e (Sistema Nacional NFS-e): standardized layout for the issuance of the NFS-e as of 2023, d) NFC-e (Nota Fiscal de Consumidor Eletrônica): used for retail sales, i.e., face-to-face sales or sales for home delivery to the final consumer (individual or legal entity), e) CT-e (Conhecimento de Transporte Eletrônico): e-invoice used for the transport of goods|
|Format for exchange with buyer/recipient||XML and PDF|
|Buyer-side requirements (AP)|
|Receiving document in electronic format||Mandatory|
|Acknowledgement of receipt||Not required - however there is a pilot project to test this|
|Response to the document received (Accept or reject)||Not possible|
|Archiving Period||5 years|
|Other Digital Reporting Obligations|
|SAF-T or other accounting filing||There’s no SAF-T in Brazil; however, it is possible to say that some blocks of information that are required for SPED files are similar in relation to their content when compared to SAF-T.|
The first legislation on e-invoicing dates back to 2005, and the e-invoicing obligation is live as of 2008. e-Invoicing was introduced in Brazil as part of a broader project focused on a national public system for e-tax accounting and e-bookkeeping (SPED).
SPED is one of the most advanced and comprehensive e-compliance systems in the world, covering e-invoicing, e-bookkeeping for tax accounting, and other e-bookkeeping related to accounting, finance, and labor law records.
What Types of Businesses Does This Apply to?
E-invoicing in Brazil is mandatory for all taxable persons supplying goods or services.
Governmental Body Responsible for E-invoicing in Brazil
- Ministry of Finance (Ministério da Fazenda)
- Federal Revenue Service of Brazil (Receita Federal do Brasil - RFB)
- Brazilian Tax Authorities on a state level (Secretaria da Fazenda - SEFAZ)
- Municipalities (Secretária de Finanças Municipal)
Penalties for Not Adhering to Brazil's E-invoice Mandates
- A penalty of up to 100% of the invoice value or transaction price may be assessed for failure to issue an e-invoice or for an invoice that does not adhere to the legal and technical requirements.
- A criminal offense may also be committed if the requirements for invoicing are not met (e.g., tax evasion).
What does the e-invoicing process in Brazil look like?
The NFS-e is generated through the municipal tax authorities webservices, provided by the respective municipal finance department, as follows:
- ISS Law allows taxpayers to issue a provisional receipt to be later replaced by a NFS-e. A Provisional Receipt for Services (Recibo provisório de serviços - RPS) can be prepared manually or via webservices
- In case RPSs are issued, these are sent in batches to the secretariat of the municipalities for processing and generating the respective NFS-e’s and receives a receipt protocol number as proof of sending the RPS batch.
- The batch received by the secretariat will be placed in a processing queue and will be executed in a timely manner. Once processed, the system returns the corresponding NFS-e or the list of errors found in the batch. Once generated, the NFS-e can no longer be changed (this also describes the process for situations in which RPSs are not issued)
Since every municipality may have its own software in Brazil that is frequently tailored for the municipality (Brazil has over 5,500 municipalities), there are many different electronic service invoice standards used across the nation. Municipalities have the option of implementing Brazil's standardized electronic service, the National NFS-e System (Sistema Nacional da NFS-e - SN NFS-e), as of 2023.
- The taxpayer generates an electronic file corresponding to the NF-e format, which contains the fiscal information of the transaction. It must be digitally signed to ensure the integrity of data and the authority of the issuer.
- The taxpayer electronically transmits the NF-e to the competent state-level Secretary of Finance (Secretaria da Fazenda - SEFAZ) of the taxpayer's jurisdiction, which will pre-validate the file and return a protocol of receipt (Autorização de Uso). The goods cannot be transported without a proper e-invoice issued and accompanying the movement of goods.
- The NF-e is transmitted to the Federal Revenue Service (Receita Federal do Brasil, or RFB) as well. The RFB operates Ambiente Nacional, a national repository for all electronic invoices issued in Brazil.
- In addition, the NF-e is sent to a different competent Secretary of Finance in the case of an interstate transaction, which is determined based on the final destination of the goods being transported.
- A shipment note called DANFE (Documento Auxiliar da Nota Fiscal Eletrônica) is printed in a single copy to accompany the transport of goods. The DANFE contains the NF-e access key that allows the holder of this document to confirm the effective existence of the NF-e through the RFB or the SEFAZ website.
The NFC-e is incorporated into the same layout as the NF-e; therefore, the process of issuing NFC-e is very similar.
Is SAF-T Needed in Brazil?
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