Tax Planning
Simples Nacional under the New Reforma Tributária do Consumo: Planning Your Tax Strategy for 2027
As Simples Nacional incorporates CBS and IBS, legal entities must understand new eligibility, timing, and revenue recognition rules to optimize tax burden and avoid pitfalls.
By NomadicTax Research Team • 7 min read • August 24, 2026
## The Changing Role of Simples Nacional
With the **Reforma Tributária do Consumo (RTC)** in full swing, Simples Nacional — Brazil’s simplified tax regime for micro and small businesses — is being fundamentally recalibrated. The regime now encompasses the **Contribuição sobre Bens e Serviços (CBS)** and **Imposto sobre Bens e Serviços (IBS)**, replacing old tax structures like PIS, Cofins, and changing treatment of ICMS & ISS.([gov.br](https://www.gov.br/fazenda/pt-br/assuntos/noticias/2026/agosto/cgsn-atualiza-regras-do-simples-nacional-para-adequacao-a-reforma-tributaria-do-consumo?utm_source=openai))
CGSN resolutions **190 and 191/2026** establish new rules that will apply **starting January 1, 2027**. These include new thresholds (sublimite rules), updated recognition of revenues, and procedural changes.([gov.br](https://www.gov.br/fazenda/pt-br/assuntos/noticias/2026/agosto/cgsn-atualiza-regras-do-simples-nacional-para-adequacao-a-reforma-tributaria-do-consumo?utm_source=openai))
## Key Planning Levers
| Aspect | What’s Changing | What to Plan For |
|--------|------------------|-------------------|
| **Sublimite threshold** | Previously, a limit of R$ 3.6M existed for some regimes — now applies also considering IBS; threshold for export uplift removed.([gov.br](https://www.gov.br/fazenda/pt-br/assuntos/noticias/2026/agosto/cgsn-atualiza-regras-do-simples-nacional-para-adequacao-a-reforma-tributaria-do-consumo?utm_source=openai)) | Businesses near the limit must assess whether remaining under Simples Nacional or migrating to regular regime yields lower cumulative tax burden |
| **Revenue recognition** | The **regime de caixa** (cash basis) is being phased out — revenue will be aligned with issuance of fiscal documents.([gov.br](https://www.gov.br/fazenda/pt-br/assuntos/noticias/2026/agosto/cgsn-atualiza-regras-do-simples-nacional-para-adequacao-a-reforma-tributaria-do-consumo?utm_source=openai)) | Entities currently using the cash regime need to model their financials under the accrual/document-based recognition to anticipate tax and cashflow impact |
| **Option periods** | Options for being taxed “por fora” (outside Simples Nacional) start in September 2026 for the 1st semester, with a deadline of March 2027 for the 2nd semester.([gov.br](https://www.gov.br/fazenda/pt-br/assuntos/noticias/2026/agosto/cgsn-atualiza-regras-do-simples-nacional-para-adequacao-a-reforma-tributaria-do-consumo?utm_source=openai)) | Entities should decide their route well ahead and prepare the necessary elections in the tax system to avoid default or delay |
## Actionable Steps for 2026–2027
- **Simulate your best case vs. worst case** under both Simples and regular regimes, factoring in new taxes IBS and CBS.
- **Upgrade invoicing and ERP systems** early, ensuring documents can reflect CBS/IBS required fields. Early missing fields may not be rejected, but missing information later can cause huge pain.
- **Consult with tax professionals** ahead of filing deadlines to understand how the rules under the new regime affect deductions, credits, and rates.
- **Review supply contracts and pricing** — since inclusion of CBS/IBS might alter cost structures, contracts may need renegotiation to handle increased tax-included costs.
## Example Strategy
A software-as-a-service startup with R$ 4 million in annual revenue expects to cross the sublimite when IBS is included. It should model:
- Its liability under Simples Nacional including CBS/IBS—does it exceed what it would pay under regular regime?
- Cost of revising contracts to pass through increased costs of taxes.
- Investment needed in system changes to comply with new invoicing rules by Jan 1, 2027.
**Net outcome**: For many small and medium businesses, staying with Simples Nacional under the new rules will make sense only if revenue stays well below thresholds and administrative upgrades are manageable.