Subtitle: Changes in CBS and IBS Collection Demand Business Attention
The Tax Reform brought significant changes with Complementary Law n° 214/2025, particularly regarding the moment when the so-called tax event occurs, or when companies must collect the new taxes, CBS (Contribution on Goods and Services) and IBS (Tax on Goods and Services). This alteration adds complexity to the process, requiring greater control from businesses.
Originally, under Bill n° 68/2024, the new taxes would be collected at the moment of supply or payment, whichever happened first. However, with the new rule established by the converted Complementary Law n° 214/2025, the tax event for CBS and IBS is now the supply of goods or services. Additionally, a new procedure has been introduced: if there is advance payment, even partial, companies must calculate and collect the new taxes based on the paid amount and the applicable rate at the time of payment.
When the supply of goods or services takes place, the paid amount will be included in the total calculation base, adjusting any differences (positive or negative) due to changes in rates. If the supply doesn’t occur (as in the case of cancellation), the paid amounts can be recovered as credit by the provider.
These changes will have a significant impact on businesses. From now on, businesses must:
* Calculate taxes at each stage – both for advance payments and the delivery of goods or services.
* Issue proper fiscal documents – every transaction must be supported and recorded by a valid electronic fiscal document.
* Monitor rate differences – if rates change between the payment and supply, the final calculation must be adjusted.
This change requires closer attention from both the provider and the customer, potentially causing extra workload and confusion, especially because it is not yet clear which document should be used for registering the advance payments.
PRACTICAL EXAMPLE
Imagine that Company A hires Company B for a R$ 200,000 service with a 12-month delivery period. The contract includes a 50% advance payment and a 50% final payment. Rates for the CBS and IBS change between the first and second year.
During the first year, Company A pays R$ 100,000 and calculates the taxes using the rates from that period (27.98%). In the second year, upon service delivery, it recalculates the tax for the full R$ 200,000 operation using the new rates (28.88%). Since the advance payment was calculated with a lower rate, the difference will be recorded as a debit for the provider and credited for the customer. In the opposite case, the higher difference will be registered as credit for the provider and must, in theory, be offset from the customer’s credit assessment. In this way, the Tax Authority guarantees partial collection of the new taxes upon advance payment, and still taxes the total value upon service delivery.
The lack of clarity regarding practical details, such as how the Tax Authority will determine the issuance of fiscal documents for advance payments, may contribute to a higher operational burden for businesses, which will have to manage a larger volume of calculations and adjustments on a monthly basis for tax reporting. This increases the complexity of fiscal activities, demanding more time and resources to ensure compliance with tax obligations.
Thus, it is advisable that when regulating Complementary Law n° 214/2025, the Tax Authority establishes a simple procedure for advance payment situations, aiming at reducing the operational burden for businesses, keeping in mind that the tax reform was based on the principles of simplification and fiscal transparency.
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