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Tax Pills #11: The Reform Calendar – When Each Thing Comes into Effect

June 30, 2026

Tax Pills: The Reform Calendar – When Each Thing Comes into Effect

 

One of the biggest pitfalls of the tax reform is the impression that there is plenty of time. The transition period runs until 2033—which seems a long way off. However, a closer look at the timeline reveals that several significant changes have already taken place, others are set for 2026 and 2027, and the pace of adaptation required is far more demanding than the total timeframe suggests.

 

What has already happened — and is already valid now

The IBS and CBS regulations have been published and are in effect. The rules for classifying rural producers—including the R$ 3.6 million threshold—are already applicable. Producers who exceeded the threshold in 2024 are already considered taxpayers as of January 1, 2026. Options to elect the standard regime can already be exercised. The Brazilian Real Estate Registry (Cadastro Imobiliário Brasileiro), which will link each rural property to the responsible taxpayer's CPF or CNPJ, is currently being implemented. Now is the time to plan for these matters.

 

2026 — the year of the CBS test

In 2026, the CBS will begin to be levied at a reduced rate as a trial and adaptation measure. The system will operate alongside PIS and COFINS, which will continue to be collected as usual during this period. The goal is to test split-payment systems, the issuance of tax documents in the new format, and the operation of credit mechanisms prior to the definitive transition. For rural producers, 2026 is the year to understand the new ancillary obligations.

 

2027 — the real transition begins

Starting in 2027, the IBS will be introduced with an initial rate of 0.1%, and the CBS will begin the process of progressively replacing PIS and COFINS. The R$ 3.6 million threshold will begin to be adjusted based on the IPCA. Presumed credit mechanisms will become fully operational. For producers and buyers throughout the supply chain, 2027 marks the need for accounting and tax systems adapted to the new environment.

 

2029 to 2032 — phased replacement

During this period, the IBS and CBS rates will rise in annual stages, while the ICMS and ISS are progressively phased out. For the agribusiness sector, this is the most critical phase: long-term contracts currently established under the ICMS framework will need to be renegotiated; tax management systems will have to operate under two regimes simultaneously; and the entire supply chain—from producer to final consumer—will be undergoing a process of adaptation.

 

2033 — the full system

By 2033, the new tax system will be fully in effect. ICMS and ISS will be abolished. PIS and COFINS will be replaced by the CBS. The IBS will be applied at the reference rate. For those who prepared over the preceding years, 2033 will confirm a well-managed adaptation process. For those who waited to understand the rules, it will mark the beginning of a period of forced adjustments.

 

Seven years seems like a long time. But when it comes to reorganizing corporate structures, renegotiating long-term contracts with cooperatives and trading companies, adapting ERP and accounting systems, training teams, and revising pricing policies—time is already running out.

 


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If you have any questions about the topics covered in this publication, please contact any of the lawyers listed below or your usual Mazzucco&Mello contact.

João Paulo Toledo de Rezende

+55 11 3090-9195

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