Brazil's tax reform and what changes for an importer

The short answer

EC 132/2023 sets the calendar: 2026 is a test year, 2027 is when CBS actually starts collecting and PIS/COFINS end, 2029 to 2032 phase ICMS and ISS down, and 2033 abolishes them. LC 214/2025 fills in the mechanics for imports specifically, and several of its own articles, read directly rather than through a summary, answer questions this reform generates most often: when the tax is triggered, what the base includes, and who is liable when a foreign platform is involved.

The schedule, from EC 132/2023

Re-read against the constitutional text on planalto.gov.br, 24 September 2026.

Practical consequence for 2026: the current tax stack (II, IPI, PIS/COFINS-Importação, ICMS) is still the one that runs your landed cost; see how Brazil's import taxes cascade for the mechanics. The reform runs alongside it as a reporting obligation this year, not yet a charge.

What LC 214/2025 actually says about import, article by article

These articles were opened and read directly rather than summarised from a secondary source, since the underlying pack flagged them as unconfirmed.

Article 65 sets the taxable event for import of goods: the entry of foreign goods into national territory. A sole paragraph presumes goods listed as imported to have entered the country where their loss is detected by the customs authority, except for baggage and international postal shipments.

Article 67 fixes when that taxable event is considered to occur: at release of goods submitted to despacho para consumo (clause I); at release under the special customs regime of temporary admission for economic use (clause II); or, for goods counted as baggage, goods on a manifest whose loss the customs authority detects, or imported goods with no import declaration at all, at the moment the corresponding tax credit is assessed (clause III).

Article 69 sets the calculation base: the customs value, plus the import duty, the Imposto Seletivo, the Siscomex fee, AFRMM, CIDE-Combustíveis (on petroleum, natural gas and ethyl alcohol fuel), anti-dumping duties, countervailing duties, safeguard measures, and any other tax, fee, contribution or duty levied on the imported goods up to their release. IPI, ICMS and ISS are not part of this base.

Article 78 lets a taxpayer under the regular IBS/CBS regime, and a buyer of goods taxed under the international remittance regime of article 95, credit the IBS and CBS actually paid on import of goods, subject to the general credit rules in articles 47 to 56.

Article 22 makes a digital platform, even one domiciled abroad, liable for IBS and CBS on transactions and imports it intermediates: jointly with the buyer and in the supplier's place when the supplier is resident or domiciled abroad; jointly with the supplier when the supplier is resident in Brazil. A platform that does not control any essential element of the operation is not liable under this article.

Article 454 provides that from 1 January 2027, IPI rates are reduced to zero for products currently taxed below 6.5%, where those products were industrialised in the Manaus Free Zone in 2024 or had an approved technical-economic project before the law's publication; the full conditions run to a third paragraph not reproduced here.

Articles 71 and 76 of LC 214/2025 were not confirmed against the primary text while preparing this page; treat any secondary summary of them as unverified until checked directly.

What is not settled yet

The CBS reference rate for 2027 has not been set as of 24 September 2026. No data on the actual figure, and a "27.91%" combined rate circulating in one secondary commercial source should not be treated as a rate. A 15 December 2026 deadline for the Senate to approve the reference rate is reported in secondary sources; the specific article of LC 214/2025 that sets that date was not confirmed against the law text while preparing this page. The Adicional COFINS-Importação surcharge, running at 0.8, 0.6 and 0.4 percentage points for 2025 through 2027 (Lei 10.865/2004 article 8 §21-A, as amended by Lei 14.973/2024), has no stated treatment once COFINS itself is extinguished in 2027: no data, and this page will not guess at one.

Sources

• Schedule: EC 132/2023, articles 125-129, re-read on planalto.gov.br 24 September 2026.
• Import-specific mechanics: LC 214/2025, articles 22, 65, 67, 69, 78 and 454, read directly on planalto.gov.br (articles 71 and 76 not confirmed).
• IBS/CBS test-year practice and e-invoice fields: see what an importer must file for the dates and the acts behind them.
• Adicional COFINS-Importação schedule: Lei 10.865/2004 article 8 §21-A, as amended by Lei 14.973/2024.
• 15 December 2026 Senate deadline for the CBS reference rate: reported by a secondary source (APET), which itself attributes it generally to "Lei Complementar nº 214, de 2025" without naming an article; the specific article was not located in the primary text while preparing this page.

Rates and the schedule verified 23-24 September 2026. The CBS rate for 2027 is genuinely unknown at the time of writing; do not build a pricing model around an estimate for it.