In brief

On 14 January 2026, Complementary Law No. 227/2026 (“CL No. 227/2026”) was published, marking the second stage of implementation of the Consumption Tax Reform.

The law derives from the conversion of Bill No. 108/2025, sanctioned by the President during the launch event of the Tax Reform Portal, held last Tuesday in Brasília.

In more detail

The law has the following main points:

  • Creation of the IBS Management Committee (CGIBS), a public entity responsible for administering the IBS, a tax created in the context of the Consumption Tax Reform and shared by states, the Federal District, and municipalities.
  • Establishment of general rules regarding administrative tax litigation related to IBS, including the creation of the IBS Superior Chamber, responsible for standardizing case law.
  • Definition of general rules for the tax transition, as well as the compensation and reimbursement of ICMS credits.
  • Modification and nationwide consolidation of general rules related to the Inheritance and Donation Tax (ITCMD), under the competence of states and the Federal District.
  • Relevant amendments to Complementary Law No. 214, published on 16 January 2025, which instituted IBS, Contribution on Goods and Services (CBS), and the Selective Tax – taxes created in the context of the Consumption Tax Reform.

 

Points of attention

The final version of CL No. 227/2026 differs from the text approved by the House of Representatives in December 2025, due to presidential vetoes of Bill No. 108/2025 for reasons of public interest.

Next steps

The enactment of CL No. 227/2026 represents a significant milestone in the implementation of the Consumption Tax Reform. The next step will be the publication of regulations through administrative acts aimed at detailing and operationalizing the application of the new legislation.

Adriana Stamato, Trench Rossi Watanabe Partner, and Mariana Maia, Trench Rossi Watanabe Associate, have contributed to this legal update.

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*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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