<\/p>\n
CGSN Resolution No. 186\/2026 was published in the Brazilian Official Gazette on April 17, 2026, establishing the deadlines and conditions for opting into the Simples Nacional regime and, additionally, allowing Simples Nacional taxpayers to calculate IBS and CBS under the regular tax regime (outside the Simples Nacional Collection Document \u2013 DAS).<\/p>\n
The regular regime refers to the system applicable to taxpayers subject to the Actual Profit (Lucro Real) and Presumed Profit (Lucro Presumido) regimes, under which these taxes are calculated separately, subject to their own tax rates, disclosed in tax documents, governed by a full non-cumulative system, and accompanied by the possibility of claiming and offsetting tax credits throughout the supply chain. These rules will apply as of the 2027 calendar year, in accordance with Complementary Laws No. 123\/2006, No. 214\/2025, and No. 226\/2026.<\/p>\n
Deadline for Election<\/strong><\/p>\n The election to join Simples Nacional for 2027 must be made between September 1 and September 30, 2026, through the Simples Nacional Portal, becoming effective on January 1, 2027. During the same period, taxpayers may also elect, where applicable, to calculate IBS and CBS outside the unified regime.<\/p>\n The application may be withdrawn until the last day of November 2026. If the request is denied, taxpayers will have up to 30 days from the date of notification to regularize any outstanding issues, including tax liabilities.<\/p>\n Calculation of IBS and CBS Outside Simples Nacional<\/strong><\/p>\n For the period from January through June 2027, Simples Nacional taxpayers may choose to pay IBS and CBS under the regular regime. In this case, these taxes will no longer be included in the DAS and will instead follow the rules applicable to companies subject to the Actual Profit or Presumed Profit regimes.<\/p>\n In practice, this measure introduces a hybrid model: the company remains within Simples Nacional while becoming subject to the non-cumulative framework for IBS and CBS, including the possibility of claiming tax credits.<\/p>\n Practical Impacts and Key Considerations<\/strong><\/p>\n This decision should not be viewed as neutral in the short term. Although the regime allows the use of tax credits, taxpayers will generally be required to pay IBS and CBS outside the DAS, which may have a direct impact on cash flow, particularly while the split payment system is not yet fully operational.<\/p>\n The change may also require a review of pricing structures and contractual arrangements, especially in service relationships, where maintaining net compensation levels may necessitate adjustments to the gross value of contracts.<\/p>\n Newly Established Companies<\/strong><\/p>\n For companies incorporated between October 1 and December 31, 2026, the relevant elections will be made at the time of registration with the Brazilian Corporate Taxpayer Registry (CNPJ) and will become effective immediately, in accordance with the applicable regulations.<\/p>\n Final Provisions<\/strong><\/p>\n The resolution does not apply to SIMEI taxpayers.<\/p>\n Final Remarks<\/strong><\/p>\n The choice of how IBS and CBS will be calculated within the Simples Nacional framework represents an important strategic decision in the context of Brazil\u2019s tax reform transition. Its effects will vary depending on each company\u2019s operational structure, tax credit profile, and contractual dynamics.<\/p>\n A prior and individualized assessment will be essential to mitigate risks and identify opportunities.<\/p>\n Our firm remains available to assist with scenario analysis, impact assessments, and the implementation of measures necessary to ensure a smooth transition to the new regime.<\/p>","protected":false},"excerpt":{"rendered":" CGSN Resolution No. 186\/2026 was published in the Brazilian Official Gazette on April 17, 2026, establishing the deadlines and conditions for opting into the Simples […]<\/p>\n","protected":false},"author":1,"featured_media":234,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[1],"class_list":["post-445","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-noticia"],"acf":[],"_links":{"self":[{"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/posts\/445","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/comments?post=445"}],"version-history":[{"count":2,"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/posts\/445\/revisions"}],"predecessor-version":[{"id":549,"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/posts\/445\/revisions\/549"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/media\/234"}],"wp:attachment":[{"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/media?parent=445"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/bvp.adv.br\/en\/wp-json\/wp\/v2\/categories?post=445"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}