Brazil has taken another major step in implementing its indirect tax reform. The country has issued the core rules for its new dual VAT-style system: Decree No. 12,955/2026, which regulates the federal CBS, and CGIBS Resolution No. 6/2026, which regulates the state, Federal District and municipal IBS. These are complemented by Ato Conjunto RFB/CGIBS No. 1/2025, which sets the initial electronic fiscal-document transition rules.

For non-resident suppliers and digital platforms, the new rules are more than a technical update. They expand the circumstances in which cross-border digital, remote and intangible supplies consumed in Brazil fall within the new tax framework, and they shift more compliance responsibility onto the platforms and systems that intermediate, document and settle those transactions.

Two shifts stand out.

First, digital platforms, including foreign platforms, can become responsible for CBS and IBS on transactions and imports they intermediate. Where the underlying supplier is foreign, the platform is responsible in substitution for that supplier, jointly with the Brazilian acquirer or recipient. Where the supplier is domestic, platform liability generally arises where reporting or fiscal-document obligations are not met.

Second, a wider population of foreign suppliers may fall within Brazilian tax scope. Destination-based place-of-supply and import rules bring remote services, digital supplies and intangibles into the framework where they are consumed in Brazil or supplied to Brazilian acquirers or recipients.

What is Brazil’s new dual VAT system? CBS and IBS explained

Brazil’s tax reform replaces several existing indirect taxes with two main VAT-style taxes:

• CBS, a federal contribution replacing PIS/Pasep and Cofins; and
• IBS, a state, Federal District and municipal tax replacing ICMS and ISS.

The CBS and IBS rules are closely aligned on many core topics, including taxable transactions, imports, exports, place of supply, platform responsibility, electronic fiscal documents and split payment.

For a broader overview of Brazil’s tax reform and how it affects the country’s e-invoicing landscape, see our previous post: Brazil’s E-Invoicing Landscape and the 2026 Tax Reform.

For businesses, this means the reform will affect more than tax calculation. Companies will need to adapt customer-location logic, invoicing flows, reporting processes, payment data and ERP or tax-engine configurations.

Why customer location matters for CBS and IBS compliance

A central feature of the reform is Brazil’s move toward destination-based taxation. Taxability is now linked to where goods are delivered, where services are consumed, or where the acquirer or recipient is located.

This is especially important for remote services, digital supplies and intangibles. A non-resident supplier may perform a service entirely outside Brazil, but the supply may still fall within the CBS/IBS framework if it is treated as consumed in Brazil.

For many services and intangibles not covered by a specific place-of-supply rule, the rules look to the principal domicile of the Brazilian acquirer. If the acquirer is outside Brazil, the rules may look to the principal domicile of the Brazilian recipient.

This makes customer and recipient location data a key compliance input for cross-border and platform-based business models.

Which foreign suppliers are in scope for CBS and IBS? 

The regulations apply to imports of goods, services and intangibles regardless of whether the importer is an individual, a company or an unincorporated entity, and regardless of whether that person is registered under the regular tax regime.

For imported services and intangibles, the Brazilian acquirer is generally the taxpayer. If the acquirer is non-resident, the Brazilian recipient may become the taxpayer. The foreign supplier can also be jointly and severally liable alongside the Brazilian taxpayer.

The rules do not create a simple “register, charge and remit” model for every foreign supplier. The outcome depends on the transaction structure, whether a digital platform is involved, and whether the foreign supplier or platform is registered. If a foreign supplier or platform is not registered under the regular regime, CBS/IBS will be collected at reference rates through the foreign-exchange remittance mechanism.

For non-residents, the key questions are:

• is the supply consumed in Brazil?
• who is the Brazilian acquirer or recipient?
• is the transaction an import of services, intangibles or goods?
• is a digital platform involved?
• is the foreign supplier or platform required to register?
• could the foreign-exchange remittance fallback mechanism apply?

What counts as a digital platform under Brazil’s CBS and IBS rules?

The regulations include a specific definition of digital platform.

A digital platform is an entity that intermediates non-face-to-face or electronic transactions or imports between suppliers and acquirers, and controls at least one essential element of the transaction, such as:

• charging or billing;
• payment;
• terms and conditions; or
• delivery.

The rules also include exclusions. An entity is not treated as a digital platform merely because it only provides:

• internet access;
• regulated payment services;
• advertising; or
• supplier search or comparison tools, where the service is not charged based on sales made.

This definition is important because platform status can trigger tax responsibility, reporting obligations, split-payment data duties and potential fiscal-document obligations.

How platforms become liable for CBS and IBS 

Digital platforms, including platforms domiciled outside Brazil, can become responsible for CBS and IBS on transactions carried out through them.

The strongest rule applies to imports. Where an import is carried out through a digital platform, the platform is expressly responsible for payment of CBS/IBS, even if the platform is resident or domiciled abroad.

Where the underlying supplier is foreign, the platform is responsible in substitution for that supplier, jointly with the Brazilian acquirer or recipient. 

Where the supplier is resident or domiciled in Brazil, the platform is jointly liable with the supplier if:

• the platform fails to provide required transaction information;
• the domestic supplier is a taxpayer and fails to issue the required fiscal document for the platform transaction; or
• the transaction is not recorded in a fiscal document.

This is a meaningful reallocation of tax risk toward the platforms that intermediate Brazilian transactions. It will be particularly relevant for marketplaces, app stores, SaaS marketplaces, delivery platforms, travel platforms, mobility platforms and other businesses that connect Brazilian customers with underlying suppliers.

What are the platform reporting obligations under CBS and IBS?

Platforms must report information on operations and imports carried out through them. This includes identifying the underlying supplier, even where that supplier is not itself a taxpayer.

The detailed reporting format, channel, timing and technical process are not fully defined yet. These will be set out in future RFB/CGIBS joint acts.

Platform reporting is expected to operate alongside the electronic fiscal-document framework, but the regulations do not yet say that issuing a fiscal document automatically satisfies the platform’s separate reporting obligation.

Platforms should therefore plan for a dedicated transaction-data reporting requirement, not just an invoicing requirement.

CNPJ registration requirements for foreign suppliers and digital platforms

Persons liable for CBS or IBS as taxpayers or responsible parties must register through the CNPJ before beginning activities.

This obligation expressly includes digital platforms domiciled abroad. Non-resident suppliers also have registration obligations where they are taxpayers or responsible parties under the CBS/IBS rules.

The regulations do not provide a general registration threshold for non-resident suppliers or platforms. Businesses should not assume that a minimum sales or revenue threshold applies before registration or platform responsibility becomes relevant.

Where a foreign supplier or foreign platform is not registered under the regular regime, CBS/IBS will instead be collected at reference rates on remittances to that supplier or platform by the institution carrying out the foreign-exchange transaction.

How e-invoicing becomes the compliance backbone

Brazil already has one of the world’s most mature electronic fiscal document systems. The new CBS/IBS rules build directly on that infrastructure.

CBS/IBS compliance will rely on electronic fiscal documents, including existing document types such as NF-e, NFC-e, NFS-e, etc. 

The framework also introduces new document types, including:

• NFAg: Electronic Water and Sanitation Invoice;
• DeRE: Specific Regimes Declaration;
• NF-e ABI: Electronic Invoice for the Sale of Real Estate; and
• NFGas: Electronic Gas Invoice.

The detailed technical layouts and use cases for these new documents still depend on further RFB/CGIBS technical rules.

For domestic-supplier transactions, a platform may, with supplier consent, issue fiscal documents in the supplier’s name. If the platform elects to act as substitute taxpayer for a domestic supplier, it must issue fiscal documents for the substituted supplier’s transactions, including on a consolidated basis.

For imports of services and intangibles, a future RFB/CGIBS joint act may require the Brazilian importer to issue a fiscal document. Even where a fiscal document is not required, importers may need to retain supporting transaction and payment records for presentation to the tax authorities.

The regulations also contemplate consolidated fiscal documents more broadly, including in certain platform scenarios. Future RFB/CGIBS joint acts are expected to regulate consolidated fiscal documents for simplification purposes, but the detailed mechanics remain pending.

How split payment turns payment data into tax data

Split payment is another key feature of the new framework.

Under split payment, payment service providers and payment-system operators will segregate and remit CBS/IBS at the time of financial settlement. The mechanism is expected to apply across payment methods such as Pix, boleto, cards, TED, TEF, vouchers and other arrangements specified by implementing rules.

For platforms, the key point is that where the platform originates the payment transaction, it must provide the information needed to enable CBS/IBS segregation and collection through split payment, where split payment is available.

The detailed technical mechanics, including format, channel, timing and system integration requirements, remain subject to future RFB/CGIBS joint acts and technical rules.

The rules also include a platform safe harbour for domestic-supplier transactions. A digital platform will not be held responsible for differences between the amount of CBS and IBS collected and the actual tax due by a supplier resident and domiciled in Brazil if:

• split payment was available during financial settlement;
• the platform correctly provided the required split-payment information; and
• the platform submitted the required reporting information.

For platforms, this means tax determination cannot sit separately from payments. Supplier data, customer data, tax calculation, fiscal documents and payment flows will need to connect.

Key CBS and IBS compliance deadlines and timeline

The critical deadline is 1 August 2026. From that date, the new CBS/IBS electronic fiscal-document requirements become enforceable, and businesses may face penalties for failing to include required CBS/IBS information where applicable.

Foreign digital platforms and other parties that are liable as taxpayers or responsible parties under the CBS/IBS rules must also register through Brazil’s CNPJ tax identification system before commencing activities.

2026 remains a transition year. Under Ato Conjunto RFB/CGIBS No. 1/2025, CBS/IBS assessment during 2026 is informational and should not create tax effects, provided the required ancillary obligations are complied with.

Separately, the CBS and IBS regulations provide a 60-day cure mechanism for certain 2026 accessory-obligation infractions. If an infraction notice is issued during 2026, the taxpayer must be given 60 days to correct the omission identified by the tax authority, and timely correction extinguishes the penalty.

The practical implication is clear: businesses must be operationally ready by 1 August 2026, while using the rest of 2026 to test and stabilise systems before financial tax exposure expands from 2027 onward.

From 2027 onward, the regime moves into broader operational implementation, with CBS and IBS rates and transition rules applying progressively.

What CBS and IBS guidance is still pending?

Several important operational details remain pending and will be addressed through future RFB/CGIBS joint acts.

These include:

• Platform reporting formats and channels: detailed procedures for how digital platforms must submit transaction data and identify underlying suppliers.
• Electronic fiscal document layouts and validation rules: technical specifications, mandatory fields, validation rules and transmission protocols for electronic fiscal documents and the national shared data environment.
• Consolidated fiscal document mechanics: specific rules for when platforms and other taxpayers may issue consolidated fiscal documents for simplification purposes.
• Split payment implementation: procedural standards, technical layouts and phased rollout rules for CBS/IBS segregation and remittance at financial settlement.
• Foreign-trade fiscal document rules: specific rules for electronic fiscal documents in foreign-trade operations, including imports of services and intangibles.
• CNPJ registration procedures: technical registration procedures for foreign parties, including foreign digital platforms and non-resident suppliers that are taxpayers or responsible parties under the CBS/IBS rules.

These future rules will be critical for final system design, especially for digital platforms, payment service providers and non-resident suppliers with Brazilian customers. Businesses will need adaptable systems that can respond as the technical mechanics are finalised.

How should your business prepare for CBS and IBS?

If your business supplies digital services, intangibles or goods into Brazil, or intermediates transactions through digital platforms, start preparing for the mandate changes with three questions.

CBS and IBS place of supply: Do you know where exactly your Brazilian customers are?

Systems need to capture acquirer location, recipient location and customer status to support destination-based tax determination.

Platform reporting: Can you identify every underlying seller?

Platform reporting is no longer a seller-only issue. Platforms must be able to identify suppliers, including suppliers that are not themselves CBS/IBS taxpayers.

E-invoicing and split payment: Are your systems ready for Brazil’s infrastructure?

CBS/IBS compliance runs through electronic fiscal documents and split-payment data. ERP, tax engine, e-invoicing and payment integrations need to be assessed together.

Brazil CBS and IBS: frequently asked questions

What are the CBS and IBS rates?

The CBS and IBS rates have not yet been finally set. The reform legislation provides for rates to be phased in progressively from 2027. During 2026, CBS and IBS assessment is informational and does not create financial tax effects, provided ancillary obligations are met. Businesses should monitor future RFB/CGIBS joint acts for confirmed rate announcements.

Is there a revenue threshold before CNPJ registration is required?

No. The regulations do not provide a general registration threshold for non-resident suppliers or digital platforms. Registration is required before commencing activities where a business is a taxpayer or responsible party under the CBS/IBS rules. Businesses should not assume a minimum sales or revenue threshold applies.

Does CBS/IBS apply to SaaS supplied to Brazilian businesses?

Yes, in most cases. SaaS supplied remotely to a Brazilian business acquirer is likely to fall within the CBS/IBS framework as an imported service or intangible. The Brazilian business acquirer would generally be the taxpayer, though the foreign supplier may be jointly and severally liable. Where a digital platform intermediates the transaction, platform responsibility rules may also apply.

Are B2B and B2C transactions treated differently under CBS and IBS?

The regulations distinguish between acquirers and recipients, and between registered and unregistered parties, rather than using a simple B2B/B2C split. For B2B transactions, the Brazilian business acquirer is generally the taxpayer on imports. For B2C transactions involving a foreign supplier or platform, the compliance mechanism may differ, including through the foreign-exchange remittance fallback where the supplier or platform is not registered.

How does the foreign-exchange remittance fallback mechanism work in practice?

Where a foreign supplier or foreign digital platform is not registered under the regular CBS/IBS regime, CBS and IBS are collected at reference rates on the remittance to that supplier or platform by the financial institution carrying out the foreign-exchange transaction. This means the tax is effectively withheld at the point of payment rather than declared and remitted by the supplier directly. The detailed mechanics remain subject to further implementing rules.

How do the new CBS/IBS rules interact with Brazil's existing tax treaties?

Brazil's tax treaties are primarily income tax treaties and do not generally cover indirect taxes such as CBS and IBS. CBS and IBS are consumption taxes modelled on VAT, and VAT-style taxes are typically outside the scope of OECD-model income tax treaties. Businesses should take specific advice on their treaty position, but treaty protection is unlikely to exempt a supply from CBS/IBS where the destination-based place-of-supply rules bring it within scope.

What happens if a foreign supplier misses the August 2026 deadline?

From 1 August 2026, CBS/IBS electronic fiscal document requirements become enforceable and penalties may apply for non-compliance. However, the regulations include a 60-day cure mechanism for certain accessory-obligation infractions during 2026: if an infraction notice is issued, the taxpayer has 60 days to correct the omission, and timely correction extinguishes the penalty. From 2027, the regime moves into broader operational implementation and financial tax exposure increases, making early preparation important.

Will there be any grandfathering for contracts signed before the reform?

The regulations do not provide a general grandfathering exemption for existing contracts. CBS and IBS apply based on when a taxable transaction occurs, not when the underlying contract was signed. Businesses with long-term contracts that predate the reform should review their contractual tax clauses and pricing structures to assess whether CBS/IBS costs can be passed on or will need to be absorbed.