CBS and IBS in Tax Reform: practical impacts for companies in 2025
Tax Reform

CBS and IBS in Tax Reform: practical impacts for companies in 2025

Guilherme PagottoPor Guilherme Pagotto
8 min read

CBS and IBS replace five current taxes with a simplified, non-cumulative model. Understand the mechanics, practical impacts, and what to expect during the transition.

❌ Current System (5 taxes)
PIS/Cofins (federal)
IPI (federal)
ICMS (state)
ISS (municipal)
Partial non-cumulative
✅ New System (2 taxes)
CBS (federal)
IBS (state/municipal)
Fully non-cumulative
Unified national legislation
Destination principle

What Are CBS and IBS?

CBS (Contribution on Goods and Services) is the federal tax replacing PIS, Cofins, and IPI. IBS (Tax on Goods and Services) is the state/municipal tax replacing ICMS and ISS. Combined, they form the dual VAT (Value Added Tax) model.

The Non-Cumulative Model

Non-cumulative taxation means taxes are charged only on the value added at each stage. Example: Manufacturer buys raw materials for BRL 100 and pays BRL 27 in taxes. Sells finished product for BRL 200 and pays BRL 54 in taxes. Credits the BRL 27 paid on inputs. Net tax due: BRL 54 - BRL 27 = BRL 27.

Transition Timeline

2026: Testing Phase

CBS and IBS begin at 1% to test systems. Companies must issue dual invoices (old and new formats) and adapt processes.

2027-2032: Gradual Increase

Old taxes (PIS, Cofins, ICMS, ISS, IPI) are phased out gradually while CBS and IBS rates increase proportionally each year.

2033: Full Implementation

Only CBS and IBS remain. Old taxes are fully replaced.

Standard Rate and Exceptions

Standard combined rate (CBS + IBS): Estimated at 26.5% (subject to government adjustment). Reduced rates and exemptions apply to: National Basic Basket (zero rate), healthcare and education (50% reduction), public transport (40% reduction), selected culture and sports services (40-60% reduction).

Destination Principle

IBS is collected where the product or service is consumed (destination), not where it is produced (origin). For interstate commerce: Seller does not collect IBS (or collects and transfers to destination state). Buyer's state collects IBS. For export: CBS and IBS are zero-rated (exports are exempt). Importers pay full CBS and IBS on entry.

Practical Impacts by Sector

Commerce (Retail and Wholesale)

  • Higher effective rate: Current PIS/Cofins (3.65%) + ICMS (varies 7-18%) vs. CBS + IBS (26.5%). For many, net burden increases
  • Credit management: Need to properly track input credits to reduce effective rate
  • Interstate sales: Must understand destination principle for IBS

Services

  • Increase for most services: Current PIS/Cofins (3.65%) + ISS (2-5%) vs. CBS + IBS (26.5%)
  • Sectors with reduced rates (healthcare, education): Benefit significantly
  • Complex services (consulting, technology): Must review pricing to maintain margins

Industry

  • Benefits from full non-cumulative model: Can credit all inputs including services
  • Loss of IPI credits: IPI is currently creditable; with replacement by CBS, credit dynamics change
  • Reorganization of production chains: Vertically integrated operations may need reassessment

What Companies Should Do Now?

1. Map Your Current Tax Burden

Calculate exactly how much you pay today in PIS, Cofins, ICMS, ISS, and IPI. This is your baseline for comparison.

2. Simulate CBS + IBS

Apply the 26.5% rate (or specific reduced rate if applicable) to your revenue. Simulate credits from inputs and calculate net effective burden.

3. Assess Credit Management Capacity

Do you track all input invoices correctly? Can you identify what is creditable? Your systems must be ready for rigorous credit control.

4. Review Pricing and Margins

If your tax burden increases, how will you adjust? Pass on to customers? Absorb and reduce margins? Optimize costs?

Conclusion

CBS and IBS represent the biggest change in Brazilian taxation in decades. For some businesses, the impact is positive (full credit, reduced rates). For others, burden increases significantly. What matters is acting early: map, simulate, prepare. Those who wait until 2026 will face crisis. Those who prepare now will adapt smoothly.

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Guilherme Pagotto

Guilherme Pagotto

Diretor Tributário

Contador, especialista em tributação empresarial e planejamento tributário estratégico. Mais de 15 anos de experiência em reforma tributária e estruturas societárias.

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