Tax reform: advances and adjustments to keep on the radar in June

CNPJ for individuals taxpayers

Federal Revenue Service extends CNPJ registration requirement for IBS and CBS individual taxpayers

In December 2025, through a Joint Communication, the Federal Revenue Service and the IBS Steering Committee established that individuals qualifying as IBS and CBS taxpayers would be required to register with the CNPJ as of July 2026.

However, in news published on June 26, 2026, the Federal Revenue Service announced the extension of this requirement to January 2027.

The communication also indicates that a simplified CNPJ registration system will be made available in November 2026, together with the implementation of training measures for these new taxpayers.

The topic is particularly relevant for sectors with significant interaction with individual suppliers, notably in transactions involving real estate activities, as it directly affects operational adaptation and compliance with obligations under the new tax regime.

Court regulates CBS/IBS rates approval

Federal Court of Accounts regulates approval of CBS and IBS reference rates

On June 10, 2026, the Federal Court of Accounts (TCU) published a resolution addressing the approval of the methodologies and calculation of the CBS and IBS reference rates in the context of implementation of the tax reform.

The rule establishes guidelines on the TCU’s role in this process, including the definition of its institutional powers, the procedures applicable to processing the projects and the rules for internal deliberation.

Among the highlights, the resolution determines that the TCU must send the CBS and IBS reference rates to the Federal Senate by September 15 of each year. In addition, the Court’s review of the calculations must occur at least 48 hours before the deadline for submission to the Senate, ensuring sufficient time to consolidate the information.

Technical Note updates NFS-e layout

Technical Note updates NFS-e layout for tax reform requirements

On June 4, 2026, Technical Note No. 009 – NFS-e was published, introducing updates to the layout of the Electronic Services Invoice (NFS-e) to adapt the document to requirements arising from the tax reform.

Among the main changes, the following stand out:

– Update of the CNPJ field: the layout now contemplates the new alphanumeric CNPJ format, whose adoption will be mandatory as of July 2026;

– Issuance of adjustment notes: issuance of debit and credit notes through the NFS-e is authorized. The debit note is intended to record an increase in the tax due, while the credit note may be used to formalize its reduction; and

– Rules for real estate transactions: specific provisions were introduced for real estate transactions, including the creation of the “gLocacao” group, intended to record information relating to the lease, onerous assignment or rental of real estate, which will serve as the basis for calculating the amounts of services provided, as well as the “gUnidImob” group, which will allow identification of the real estate units involved in the transactions.

The changes require taxpayers’ attention to the adaptation of their systems and internal processes.

Use of PIS/Cofins credits

Use of PIS and Cofins credits after the tax reform: Federal Revenue Service guidance

Complementary Law No. 214/2025 established that PIS and Cofins credits may be used by taxpayers even after the extinction of those contributions scheduled for 2027. In this context, such credits may be used to offset CBS debts, be refunded in cash, or be offset against other federal taxes, subject to the applicable legal requirements.

In addition, on June 3, 2026, the Federal Revenue Service published a communication clarifying that, for purposes of refund, offset against other federal taxes and offset against CBS, taxpayers must use the PER/DCOMP system, which will include a specific functionality to enable these transactions.

DeRE v1.1.0 technical documentation published

Federal Revenue Service and IBS Steering Committee publish version 1.1.0 of DeRE technical documentation

On June 22, 2026, a Joint Act of the Federal Revenue Service and the IBS Steering Committee was published, authorizing the release, on the public portals of the IBS Steering Committee and the Federal Revenue Service, of version 1.1.0 of the technical documentation package for the Specific Regimes Statement (DeRE). DeRE is part of the implementation of ancillary obligations related to the calculation of CBS and IBS by taxpayers subject to specific taxation regimes.

The technical documentation published comprises the DeRE User Guidance Manual, the statement layouts, tables, and validation rules.

The publication is particularly relevant for financial service providers, health care plan operators and entities operating prognostic contests, sectors expressly mentioned in the act. In practice, the measure allows taxpayers and developers to begin or advance the adaptation of their corporate systems, with attention to the integration, validation and consistency rules for tax and accounting information that will be required in the new IBS and CBS assessment model.

The Joint Act entered into force on the date of its publication.

NFS-e and ISS on Rental Activities

TJSP rejects ISS charge on lease of movable property recorded in NFS-e

The São Paulo State Court of Appeals (TJSP) recognized the unlawfulness of the Municipality of São Paulo’s ISS requirement on activities involving the lease of movable property. With the tax reform, the company’s leasing activities became subject to IBS and CBS and, as of January 2026, the company, whose main activity was the lease of communication devices, began issuing Electronic Services Invoices (NFS-e) to record its leasing activities in order to comply with the testing period for those taxes.

When attempting to issue the NFS-e through the National Portal, the system presented failures and incorrect registration data, making issuance unfeasible. When using the São Paulo City Hall’s own system, the company found that the system conditioned issuance of the NFS-e on the calculation and payment of ISS on the lease of movable property.

In this context, the 2nd Public Treasury Court of the District of São Paulo recognized the unlawfulness of the tax charge, ordering the municipality to refrain from requiring ISS on leases of movable property, even if recorded in the municipal NFS-e system because of the new obligations arising from the tax reform, on the grounds that the Brazilian Supreme Court had declared the illegality of ISS on leasing activities.

The TJSP stated that the taxpayer was required to issue a tax document for the new taxes under Complementary Law No. 214/2025, which the São Paulo municipal system prevented it from doing without charging ISS. However, the São Paulo court emphasized that the fact that the system was not programmed to separate the tax reform obligations from the former municipal obligations does not give the São Paulo tax authorities the right to charge ISS on activities not subject to that tax.

The São Paulo municipal tax authorities filed an appeal against the judgment, which is still pending review.

Bill in PR removes IBS/CBS/IS from ICMS

Bill in Paraná seeks to exclude IBS, CBS and the Selective Tax from the ICMS calculation base

On June 1, 2026, Bill No. 523/2026 was presented, seeking to amend the state ICMS legislation to provide that IBS, CBS and the Selective Tax are not included in the state tax calculation base. The proposal seeks to establish that ICMS continues to apply only to the value of the economic transaction, excluding the possibility of charging the state tax on the new taxes introduced in the context of the tax reform.

The bill was presented to the Legislative Assembly of Paraná and aims to insert this provision expressly into the State’s ICMS Organic Law. According to the bill’s explanatory statement, the amendment seeks to provide greater clarity to the tax treatment applicable during the tax reform transition period, especially given the coexistence of two tax systems during that period.

This publication is intended for informational purposes only and does not constitute legal advice. Our ​Indirect Tax​ team remains available to provide specific legal guidance tailored to your business needs.