Brazilian Tax Reform: Navigating 
Source-to-Pay and ERP Impacts

Brazil’s tax reform marks a pivotal shift to modern, efficient and transparent tax infrastructure. While upcoming changes are set to simplify long-term tax structure, organizations must navigate immediate pressures across Source-to-Pay (S2P), Enterprise Resource Planning (ERP), finance, and compliance functions. 

Tax Reform Breakdown

Dual Value Added Tax (VAT) Model

Brazil will replace PIS, Cofins, IPI, ICMS, and ISS with two unified taxes:

  • CBS - Federal 
  • IBS - State/Municipal

Both levied under common rules with destination-based taxation and full input credits.

  • Selective Tax (IS) - A third tax (IS) applied to certain goods deemed harmful to health or the environment, like tobacco and alcohol

Implementation Timeline

  • Testing of electronic invoicing layouts - Begins mid-2025 
  • Live use of CBS/IBS - Begins January 2026
Year
CBS/IBS Implementation
Collection Status
2026

Symbolic testing (0.9% CBS, 0.1% IBS)

No actual tax paid

2027

CBS begins to replace PIS/Cofins/IPI

Actual collection starts

2029+

Gradual replacement of ICMS and ISS by IBS

Phased transition continues

2033

Full implementation of CBS and IBS

Full phase-out of old taxes

Full transition planned to go into effect by 2027-2033, with parallel operation of legacy and new regimes during the transitional phase.  

Electronic Invoicing Update

NFe, NFCe, and other document formats are updated with new fields and validation rules for CBS, IBS, and the Selective Tax (IS).

Alphanumeric CNPJ

Starting January 2026:

  • New CNPJ identifiers will be alphanumeric (same 14-character length, but incorporating letters) for new registrations
  • Current numeric IDs will remain valid

Operational Impact on S2P & ERP

Purchase Orders & Invoice Tax Logic

  • Tax calculation must adapt to destination-based logic and new tax codes
  • ERP and S2P systems must support transaction-level CBS/IBS logic and split payments embedded in workflows 

Split Payment - Automatic Tax Witholding at Payment

Under this model, when a transaction is paid, the tax portions (IBS and CBS) are automatically separated from the payment. The buyer pays the tax amounts directly to the tax authorities, while the remainder is paid to the supplier. 

There are three planned modes based on taxpayer profiles: 

1. Standard (Intelligent Split Payment)

Used in B2B transactions. Payment processors compute the correct tax amount (accounting for credits) and remit it directly to the tax authorities at the point of payment. 

2. Simplified Split Payment

For purchasers not registered under CBS/IBS (e.g., Simples Nacional). A preset percentage is withheld and remitted, simplifying compliance. 

3. Purchaser Collection (Analog)

When automatic split isn't possible, the purchaser collects and remits tax to the tax authorities. This method is still under discussion and not fully defined. In this method, the ERP and S2P systems must be configured to calculate and apply split payments, ensuring the correct withholding of CBS and IBS tax amounts at the time of invoice settlement. 

Split Payment Example:
Scenario
Who Gets Paid

Supplier has IBS/CBS credits

Buyer pays full amount and supplier receives the total.

Supplier lacks credits or undetermined

Buyer triggers withholding and tax withheld to authorities. Remainder goes to supplier.

Read More: Split Payment Explained

Nota Fiscal Electrônica (NFe) Comliance

  • Invoice formats updated with CBS/IBS fields and validation groups
  • Systems must support both current and reform-era layouts during the transitional period

Master Data & Entity Validation

  • CNPJ fields must support both numeric and alphanumeric formats
  • Proper configuration is crucial for seamless validation and e-document integration

Integration & Reporting Workflow

  • ERP integrations with tax engines, SPED, and e-invoicing must support new schemas, APIs, and bidirectional data flows
  • Real-time credit validation, parallel regime processing, and compliance under CBS/IBS necessitate robust middleware strategies

How Optis Can Help

Challenge
Optis Approach

Dual-VAT Logic Integration

Adapt procurement, PR/PO, invoice processes, and support the ERP transition of tax flows to CBS/IBS logic, including split-payment and withholding tax configuration in S2P, with full integration to the ERP for payment.

Master Data Readiness

Audit and migrate tax codes, contact files, and CNPJ formats for seamless integration.

System Integration & Testing

Develop middleware, automate schema mapping, and test transitions across legacy and new regimes.

Training & Change Management

Train finance, supply chain, and IT teams on dual tax handling across S2P workflows.

Hypercare & Support

Provide monitoring and support during go-live periods and transition phases to mitigate disruptions.

Optis Consulting brings hands-on experience in configuring source-to-pay workflows, updating tax requirements and split payment requirements in your organization's source-to-pay, and supporting organizations through the CBS/IBS rollout. Whether you operate with numeric or alphanumeric CNPJs, need parallel regime processing, or require seamless invoice compliance, Optis helps ensure your S2P systems, teams, and operations remain compliant and operational through the transition. 

Disclaimer: The information presented on this webpage is for educational and informational purposes only. Optis Consulting is a technology and Source-to-Pay systems advisory firm. While we closely monitor Brazil’s tax reform (CBS/IBS) and help organizations prepare their S2P environments accordingly, we do not provide tax or legal advice, nor do we interpret tax legislation. 

This content reflects our understanding of system-level impacts based on publicly available resources and collaboration with S2P platform and trusted tax partners.

We recommend all organizations consult with qualified tax or legal advisors to assess their specific obligations under CBS/IBS based on industry, entity classification, and jurisdiction.

Optis Consulting supports Coupa, Ivalua and Ariba customers in configuring, optimizing, and future-proofing their systems for compliance, but does not assume responsibility for legal or fiscal determinations. 

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