Brazil: New guidelines for indirect tax reporting
New guideline will impact how upcoming indirect taxes are reported
As Brazil moves forward with its comprehensive tax reform, a new guideline has been released that will impact how upcoming indirect taxes are reported. The Practical Guide for EFD-ICMS/IPI (Version 3.2.0) (Portuguese), published on September 30, 2025, introduces a significant change for the 2026 fiscal year: the IBS (tax on goods and services), CBS (contribution on goods and services), and IS (selective tax) must be included in the total value of the fiscal document.
The main changes regarding this update include:
- Inclusion of guidance on how to fill field 04 of record D700—bringing greater clarity to the correct reporting of information.
- Addition to Chapter I of Section 10—with information related to the Tax Reform on Consumption, reinforcing the need for taxpayers to adapt to the new model that will come into force in the coming years.
- Inclusion of guidance in the K230 registry—detailing new instructions about manufactured items that should be observed as early as the beginning of 2026.
This update introduces a layer of complexity that taxpayers must prepare for, especially as it appears to contradict previous guidance from federal authorities.
Key highlights of this upcoming change include:
- Divergence between document and operation values: The new guide distinguishes between the total value of the document (valor do documento - reported in C100) and the value of the operation (valor da operação - reported in C190). While IBS, CBS, and IS will be part of the total document value, they will not be included in the operation value. This will create a recognized discrepancy between these two key figures.
- Increased compliance complexity: This requirement adds a new challenge for taxpayers just months before the national kick-off of the tax reform. The distinction will require careful adjustments in ERP and tax systems to ensure that fiscal records (SPED Fiscal) are generated correctly, reflecting the new tax amounts in the appropriate fields while excluding them from others.
- Impact on taxpayers: Businesses must now account for this new rule in their transition planning. Previously, the expectation was that the “test rates” for IBS and CBS in 2026 would simply be informational tags in the XML invoice without affecting the document's total value. This change requires a more structural adaptation to ensure compliance with the new SPED Fiscal layout.
KPMG observation
Given this development, companies may need to reassess their tax reform implementation projects to avoid compliance issues in 2026.
Along with this update, version 6.0.0 of the Program EFD ICMS IPI was published, which contains the updates mentioned above and other additional changes to the content of the validation rules to several fields and registries.
The transition to Brazil's new tax system is an evolving process. Discussions regarding tax reform are ongoing, and the guidelines, including the SPED Fiscal layout and its interaction with the new taxes, may be subject to further adjustments by the government to comply with future mandates or address technical issues.
For further information, contact a KPMG tax professional:
Paula Smith | ppsmith@kpmg.com
Atila Borba Vaccaro Pidoni Mota | atilamota@kpmg.com
Bruno Siqueira Peitl | bsiqueirapeitl@kpmg.com
Philippe Stephanny | philippestephanny@kpmg.com
Ramon Frias | ramonfrias@kpmg.com
Denis Scarassati | denisscarassati@kpmg.com