Brazil: Updates on e-invoicing changes due to tax reform

The Brazilian government presented to Congress regulations to introduce the new dual value added tax (VAT) regime under the tax reform bill. Among modifications brought by the new regulations, both residents and nonresidents doing business in Brazil will need to adapt to the ancillary changes pertaining to compliance—such as the new indirect tax liabilities for nonresident sellers or digital platforms. Read TaxNewsFlash

To Brazilian taxpayers, changes in compliance will surround the way electronic invoices and digital compliance are issued—remarkably regarding additional sets of data pertained to the new dual VAT regime corollary of the tax reform, which will replace the existing multi-jurisdiction level system.

To that end, the Brazilian government has published the initial set of changes associated to electronic invoices for goods issued by local taxpayers. The Technical Note NT 2024.002 on its version 1.00 outlines new groups of fields that will be required to be informed in the electronic invoices of goods (NF-e model 55) and electronic invoice of goods to final consumer (NFC-e model 65). It also published the SE/CGNFS-e nº 001 that outlines adjustments to the layout of the electronic invoice for services (NFS-e) in light of the consumption tax reform

Specific fields containing information about the following taxes were added to the current layout of the electronic documents:

• The contribution on goods and services (contribuição sobre bens e serviços—CBS) that would replace the federal PIS/COFINS contributions
• The tax on goods and services (imposto sobre bens e serviços—IBS) that would replace the state VAT (imposto sobre circulação de mercadorias e serviços—ICMS) and the municipal tax on services (imposto sobre serviços de qualquer natureza—ISS)
• The new selective tax (imposto seletivo) expected to be created by 2027 to tax the manufacturing, commercialization and importation of goods deemed to be hazardous to public health and the environment, such as cigarettes and alcoholic beverages

Additionally, new validation rules for the new fields and rejection messages were introduced. Those rules will be used by the local authorities as part of the existing data and structure analysis to determine the approval or rejection of each document issued.

Conscious that both taxpayers and tax authorities from the various states will need to prepare their systems to incorporate the new structure and rules, the expected implementation timeline will be as follows:

• From September 1, 2025, through October 30, 2025, changes brought by NT 2024.002 version 1 will be available at the testing environment of the electronic invoice portal.
• From October 31, 2025, through December 31, 2025, changes will be made available at the production environment of the electronic invoice portal, however, taxpayers are not expected to populate any of the additional fields—as CBS and IBS will only become effective on January 1, 2026.
• Starting on January 1, 2026, new fields and validation rules will become fully in effect.

Paula Pignatti Smith | ppsmith@kpmg.com

Atila Vaccaro Pidoni Mota | atilamota@kpmg.com