Established with the tax reform, the entity now has a full quorum and can deliberate on the organization to manage the new tax.
The Management Committee for the Tax on Goods and Services (IBS) should officially begin work next Monday (February 9th) with a virtual meeting. The public entity with technical, administrative, budgetary and financial autonomy of tax reform, established by Complementary Law (LC) 227/26, It will prioritize discussions on the agency's structural issues—steps considered essential to enabling the shared management of the new tax among states, municipalities, and the Federal District.
The Management Committee will be responsible for administering, collecting, monitoring, levying, charging, and distributing the IBS (Tax on Goods and Services), as well as regulating the tax's operational procedures. The body is composed of 54 representatives, with 27 appointed by the states and the Federal District and 27 by the municipalities, with equal participation.
To the JOTA, The Finance Secretary of Jaboatão dos Guararapes (PE), Cesar Barbosa, a member of the board appointed by the National Confederation of Municipalities (CNM), stated that the first meetings should focus precisely on the practical implementation of the legal guidelines. "In this meeting, the structural issues of the committee should be discussed, such as organization, vice-presidency, and the beginning of the drafting of the internal regulations," he said.
In addition to addressing the reform regulations, the meeting agenda should cover the swearing-in of the newly elected members, as well as the selection of the vice-president. The Committee president remains in office. Elected in August 2025, the Secretary of Finance of Mato Grosso do Sul, Flávio César Mendes de Oliveira, will serve until March 2027. Oliveira also currently chairs the National Committee of Secretaries of Finance, Revenue, or Taxation of the States and the Federal District (Comsefaz).
Structure
Although Law 227 provides for quarterly ordinary meetings, an intense schedule of extraordinary meetings is expected at the outset, given the complexity of the responsibilities assigned to the committee. The institution's headquarters should be located in Brasília (DF), but a specific location has not yet been defined. The legislation allows for virtual meetings.
By law, the Management Committee will have its own administrative structure, composed of directorates, coordinations, and technical areas, which may be staffed by employees seconded or requested from the federative entities.
Barbosa explained that the structure will be responsible for managing an estimated annual revenue volume between R$ 1.3 trillion and R$ 1.5 trillion. “It’s an enormous volume and a very large responsibility. A decision that seems small today can have major impacts in the future,” warned Barbosa, highlighting the need for legal and technical certainty in initial decisions.
Law 227 also provides for mechanisms of transparency, accountability and control, including specific rules on collegial deliberation and voting quorum.
Mandates
The initial composition of the committee is exceptional. As authorized by Law 227 itself, the first municipal representatives were appointed by national entities — CNM and the National Front of Mayors (FNP) — to ensure the swift implementation of the IBS. This transitional model will be in effect until March of next year, when the first formal election will be held, with direct voting by the mayors, concluding the nomination phase. From then on, the terms will have a regular duration of two years, with the possibility of reappointment.
Until now, the committee has operated provisionally with only state members due to a deadlock between the associations responsible for nominating municipal representatives.
In addition to institutional organization, the committee will play a central role in the sub-legal regulation of the IBS, a task also expressly assigned by LC 227. According to Barbosa, there is a preliminary regulation prepared during the pre-management committee phase, which must be reviewed and approved by the collegiate body. As previously reported... JOTA, although there is an idea to publish a “common regulation”Political factors may delay the measure.
According to sources consulted, Law 227 will not be subject to specific regulation. Any points requiring clarification will be addressed in the joint regulation of the IBS and the CBS.
Responsibilities
The legislation also assigns to the committee the responsibility for implementing the national technological system of the IBS, which will centralize collection, automatic distribution of revenue, mechanisms such as split payment and tax refunds (cashback), as well as integration with national electronic invoices and the proprietary systems of the federative entities.
The secretary emphasizes that the logic of the IBS (Brazilian VAT), based on the destination of consumption, fulfills one of the central objectives of the legislation: to end the fiscal war and strengthen the federal pact. In his assessment, with revenue linked to the place of consumption, and no longer to the origin, entities begin to compete for real economic development, and not for tax benefits. "LC 227 (Complementary Law 227) gives institutional form to this change in mentality. It is a model that requires cooperation and a long-term vision," he stated.
Taxpayer concerns
Practical aspects are a concern for lawyers, who consider the testing phase crucial for visualizing how the new system will be implemented. Among the concerns of the lawyers interviewed by [the publication/organization] JOTA There is a lack of clarity regarding litigation in cases where the same transaction is subject to both IBS and CBS.
According to tax lawyer João Rezende, partner at Mazzucco&Mello – Sociedade de Advogados, in the event of a tax assessment, the taxpayer will have to litigate before two different bodies, resulting in duplicated procedural monitoring, presentation of defenses, deadlines, interpretations, and potentially divergent conclusions.
“This institutional design goes against the stated objectives of the tax reform, such as simplification, reduction of litigation, efficiency, and reduction of administrative costs associated with compliance with tax obligations in the country,” Rezende points out.
The perception is the same as that of lawyer Milton Schivitaro Neto, from Finocchio & Ustra Advogados, who draws attention to the need for the sub-legal regulations of IBS and CBS to clarify how this joint oversight will work. “One point that could be positive would be a single regulation for LC 214, LC 227, IBS, and CBS. This delay would have a potentially positive impact, which is a single regulation,” he commented. In general, the absence of regulations has a strong impact on companies' tax planning.
Rezende also cites the automotive industry as an example, which needs greater clarity regarding the Selective Tax in order to allocate investments, assess costs and profit margins, and ultimately determine the tax burden. JOTA also added The bill that will address the IS tax rates is already ready and will be presented to congressional leaders upon their return from recess.