The year 2026 marks the beginning of the practical implementation of Brazil’s new consumption tax system, with the introduction of the CBS (federal) and the IBS (subnational)—new taxes that will gradually replace the current consumption-based levies—initially at reduced rates. More than an operational challenge, this transition phase creates a strategic opportunity. Foreign investors can test business models in an environment with limited financial exposure, anticipating decisions that will become critical once the new system is fully implemented. At the same time, the coexistence of the current regime and the new system ushers in a period of greater short-term complexity—a dynamic inherent to the transition process. Long-term simplification initially requires an overlap of rules, systems, and interpretations.

In practice, this framework creates a unique scenario. The effective tax burden remains largely tied to the current system, while the new model is introduced in parallel. This allows companies to simulate future structures, such as logistics, supply chains, and corporate organization, without being fully exposed to the financial impact these decisions will entail in the coming years.

This shift is already influencing how strategic decisions are made. Analysis is no longer based solely on current conditions but increasingly incorporates forward-looking projections of cash flows, tax credit dynamics, and operational restructuring under the new regime. Companies are effectively simulating a post-reform environment, comparing current tax burdens with those expected under the new system. This approach anticipates effects that, under normal circumstances, would only become evident after full implementation.

For foreign investors, this context reshapes the timing of market entry. The decision now involves not only assessing current conditions but also weighing the benefits of gaining early operational experience within a system still under development. Operating under two parallel regimes requires continuous adjustments and increased adaptation efforts. Still, the structure of the transition phase creates a distinct advantage: the ability to calibrate decisions with reduced immediate financial impact. “Failing to anticipate the effects of this transition carries an opportunity cost. Those who move early can test structures more safely. This is the moment when mistakes are less costly,” says Rafael Amorim, partner in the Tax practice at Vieira Rezende.

In this edition of Brazil Brief, Amorim explores how this transition is unfolding in practice and shaping corporate operations and investment structuring.

CBS and IBS: What Are the New Consumption Taxes? 

Brazil’s tax reform introduces two new taxes that will gradually replace the main consumption taxes currently in place: 

• CBS (Contribution on Goods and Services): a federal tax that will replace PIS, COFINS, and part of the IPI. 

• IBS (Tax on Goods and Services): a subnational tax that will replace ICMS (state-level) and ISS (municipal-level taxes).  

The objective of the new system is to simplify consumption taxation, reduce distortions, and align Brazil more closely with internationally adopted VAT models. 

Explore the full edition here.