Context and Key Changes for 2027
Starting in January 2027, the new consumption taxes—Contribuição sobre Bens e Serviços (CBS) and Imposto sobre Bens e Serviços (IBS)—must be incorporated into the Simples Nacional regime. Under Lei Complementar nº 214/2025 and Resoluções CGSN nº 190/191/2026, companies have options regarding how these taxes will be collected. (gov.br)
What are the Options?
- Simples Nacional “Puro”: All taxes (including CBS & IBS) are collected via a single guide (DAS). Default if no choice is made by the deadline. (gov.br)
- Simples Nacional “Híbrido”: The company stays in Simples Nacional for most taxes but chooses to collect CBS and IBS outside the unified regime, under regular rules. Beneficial for those transacting predominantly with other companies needing credit on CBS/IBS. (gov.br)
Deadlines & Effective Dates
- September 1–30, 2026: Period to opt into Simples Nacional if not already in. Also, current Simples taxpayers must decide between pure vs. hybrid model for CBS/IBS. Choices made then take effect Jan–June 2027. (gov.br)
- A second window in March 2027 allows option for the second semester (July–December 2027). (gov.br)
Practical Examples
- Example A: A small manufacturer selling mainly to large corporations might choose híbrido, enabling clients to take advantage of input tax credits under IBS/ICMS/CBS. Even though administrative burden increases, the competitive gain could justify it.
- Example B: A local service provider with mostly final consumers might stay with puro, avoiding complex bookkeeping and minimizing compliance costs.
Action Plan
- Review your revenue mix: If majority of sales are B2B, hybrid is likely better.
- Assess compliance capacity and costs: Hybrid regime involves outside-DAS registrations, different tools.
- Consult with your tax advisor by mid-September: Decisions must be registered by 30 September 2026. (gov.br)
- Monitor eligibility thresholds (sublimites): Revenue limits for inclusion of CBS/IBS remain relevant (approx. R$ 3.6 million). (gov.br)
Conclusion
Small businesses face a pivotal decision in September 2026: opt into the new tax regime structure under the Simples Nacional “puro” or adapt via a “híbrido” route. Each option carries trade-offs—simplicity vs. credit benefits. Choose based on your clients, operations, and capacity, and begin compliance preparations earlier this fall.