What’s Changing
The Reforma Tributária do Consumo (RTC) introduces two key taxes—IBS (Imposto sobre Bens e Serviços) and CBS (Contribuição Social sobre Bens e Serviços)—which replace PIS/Cofins. Under recent CGSN resolutions (Resoluções CGSN 190 e 191/2026), companies under the Simples Nacional regime must adapt to include these new taxes in their calculations, whether inside or outside the regime. (gov.br)
Key Rules & Deadlines
| Action | Who It Applies To | Period for Option | Effective Date |
|---|---|---|---|
| Opting into Simples Nacional for 2027 | New entrants or those not currently in SN | 1–30 September 2026 | From 1 January 2027 (gov.br) |
| Option to collect IBS & CBS under regular (outside Simples) regime | Existing SN businesses who want those taxes handled separately | 1–30 September 2026 for first half of 2027; alternatively, 1–31 March 2027 for second half (gov.br) | |
| Cancel the option | After opting, cancellation allowed until 30 November 2026 for the first half; 31 May 2027 for the second half (gov.br) |
How the Tax Base & Definitions Expand
- Revenue from goods (materials), intangible assets, rights, and services are now explicitly included in Simples’ gross revenue (receita bruta). (gov.br)
- Items like tips, interest, fines, surcharges, and other charges must now be accounted for. (gov.br)
- Where IBS and CBS are collected externally (outside Simples), the values counted for those do not enter the receita bruta for Simples Nacional calculation. (gov.br)
- A sublimit for inclusion of IBS now matches the threshold for ICMS and ISS: R$ 3.6 million. Exported sales keep a special higher threshold. (gov.br)
Practical Scenarios
Scenario 1: Small Retailer Currently in Simples Nacional
- You sell physical goods and some services.
- You want to simplify your obligations: stay in Simples Nacional including IBS & CBS.
- No action needed; default brings these taxes into the regime starting 1 January 2027. Your DAS will include them. Your calculations need adjusting. (gov.br)
Scenario 2: Tech Startup Opting for Simples Nacional + External CBS/IBS
- As an existing SN company, you prefer to calculate IBS & CBS under regular rules (outside Simples), perhaps because CBS has favorable credits in your business chain.
- If you take this option between 1–30 September 2026, you’ll externalize CBS & IBS for Jan–Jun 2027. If you opt later (March 2027), it only applies to Jul–Dec 2027. Cancellation windows apply. (gov.br)
Actionable Advice
- Map your revenue streams now to understand what income is goods vs. services, intangible vs. material—so you know how the new gross revenue definition will affect you.
- Evaluate which option—Simples plus inside vs. Simples plus external for CBS/IBS—is beneficial based on whether credits apply and administrative burden.
- Mark deadlines: 30 September 2026 is crucial for all option changes affecting 2027. Missing it could lock you into default treatment with no external regime until mid-2027.
- Review your billing, tax reporting software EM systems to include the new components like tips, fines, interest, surcharges, and ensure document fiscal emission aligns with RTC rules.
- Consult with a tax adviser to run scenario modelling—Simples Nationale total cost with IBS/CBS inside vs. external regime—project both cash flow and administrative costs.
Possible Risks
- Underestimating the impact on gross revenue base, pushing companies into higher brackets under Simples Nacional.
- Missing cancellation windows—once past deadline, you may be locked in undesirably.
- Audits will increase focusing on omitted revenue like fines, tips, or intangible services if not correctly documented.
- Complexity of separate CBS/IBS compliance if externalized—many rules and documentation required.