On January 13, 2026, the Executive Branch sanctioned Supplementary Bill No. 108/24, and Supplementary Law No. 227/2026 was published in the Federal Official Gazette on January 14, 2026, concluding an important operational stage of the Tax Reform that had been awaiting regulation.

It is important to recall that the transition phase related to the IBS and CBS was formally initiated in January 2026. However, the new law consolidates central aspects of the new Brazilian tax system for the implementation of the IBS.

The new legislation instituted the Management Committee of the Goods and Services Tax (CGIBS), responsible for the administration and oversight of the IBS, which will replace the ICMS and ISS, as well as addressing the administrative dispute resolution of the IBS and the distribution of tax revenues among the federative entities. The following points deserve special attention:

The IBS Management Committee (CGIBS) establishes the body responsible for administering, supervising, regulating, and distributing IBS revenues among States and Municipalities. Although the IBS is administered exclusively by the CGIBS, the law preserves the role of State and Municipal tax administrations, which remain responsible for inspection, assessment, and collection, under centralized coordination.

A single regulation and the end of normative multiplicity provide for a unified IBS regulation, approved by the Superior Council of the CGIBS, with the intention of ending interpretative divergences involving the tax, as occurred with ICMS and ISS, thereby reducing federative disputes.

The new administrative tax procedure for the IBS creates a specific, fully electronic administrative process, with express principles of legal certainty, reasonable duration of proceedings, and mandatory observance of binding precedents. It establishes specific rules for defense, judgment, appeals, and the standardization of decisions involving the IBS. It also creates the IBS Superior Chamber, responsible for unifying administrative jurisprudence at the national level, which tends to reduce divergent decisions but also concentrates interpretative authority in a single instance.

The creation of national adjudicatory bodies structures the administrative tax dispute system into three levels, highlighting the IBS Superior Chamber, responsible for the nationwide unification of administrative jurisprudence.

The binding force of administrative precedents establishes mandatory observance of decisions of the Federal Supreme Court (STF), the Superior Court of Justice (STJ), including repetitive appeals and general repercussion rulings, as well as summaries and uniform decisions of the CGIBS within the IBS dispute resolution system.

The standardization of administrative and judicial collection provides centralized coordination of administrative collection, registration of tax debts, and judicial enforcement, while preserving the ownership of the tax credit by each federative entity.

The rules for the distribution of IBS revenues define how collected resources will be shared among the federative entities.

The standardization of general rules of the ITCMD unifies rules regarding inheritance and donation tax, establishing national standards for the tax on causa mortis transfers and donations, significantly reducing the historically existing margin of legislative and interpretative divergence. On the other hand, it requires immediate attention from families and companies to review estate and succession planning in light of the new scenario.

Furthermore, the new law establishes that the State inheritance tax must be progressive, and ITCMD rates will be defined by each State, respecting the maximum rate established by the Federal Senate, meaning that the greater the value of the inheritance or donation, the higher the applicable tax rate.

At this moment, heightened attention from taxpayers is essential, especially regarding changes promoted within the scope of the ITCMD and State regulations, due to the patrimonial impacts arising from the new regulatory framework.

The team at Dupont Spiller Fadanelli Advogados closely follows the matter and remains fully available to clarify any questions on the subject.