With the enactment of Complementary Law No. 214/2025, a new reality is emerging for the real estate sector.

The entire real estate construction and commercialization chain must be prepared, from small contractors to large developers, and from self-employed brokers to property management companies.

The need for adaptation is due not only to the legal and structural changes brought about by the reform, but also to operational and strategic considerations.

The reform introduces a change in mindset for the sector, which previously did not operate under a credit and debit offsetting system, in which transactions generate tax liabilities and credits.

CBS (Contribution on Goods and Services) is the federal tax that will replace PIS/COFINS; IBS (Tax on Goods and Services) is the state and municipal tax that will replace ICMS and ISS.

Accustomed to taxing revenue and defining strategies based on Gross Development Value (VGV), the sector will now operate under an offsetting system: as a general rule, the acquisition of goods and services by market participants, such as landlords, builders and developers, generates tax credits. This is consumption taxation, with taxes charged “outside” the price.

The implementation of the new tax system began in January 2026 and will continue through 2033. In other words, this is a structural reform being implemented over a seven-year period.

In addition to the introduction of the new taxes, CBS and IBS, and their respective rates, concepts such as adjustment reduction, social reduction and reference value will become part of the daily routine not only for companies that build and sell properties, but for all players operating in the real estate market.

The reform has a broad scope. It affects the entire chain of inputs and suppliers, service providers, intermediaries and property managers, including individuals, who may become taxpayers of the new taxes depending on certain criteria.

Management systems and tax controls must be adapted to the new framework so that, during this testing period, the necessary operational adjustments and adaptations can be made.

At this initial stage, the focus will not be on revenue collection, but rather on adapting to the new model, with symbolic rates of 0.1% for IBS and 0.9% for CBS, as well as the possibility of offsetting these amounts against PIS/COFINS or even obtaining a refund.

This testing period has already reached an important milestone: on April 30, 2026, Decree No. 12,955/2026 and CGIBS Resolution No. 6/2026 respectively regulated CBS and IBS, giving operational substance to the provisions of Complementary Law No. 214/2025. These regulations established a tolerance period that ended on July 31, 2026. As of August 1, 2026, errors and omissions in IBS and CBS fields on electronic invoices became subject to penalties, based on Article 341-G of Complementary Law No. 227/2026. In practice, this has already resulted in the rejection of tax documents as of the following business day, August 3. Revenue collection remains not the central objective of this phase, but tolerance for operational errors is now lower than it was through July.

It is estimated that, by 2033, the effective combined IBS/CBS rates will be 14% for the sale of real estate, the creation of real rights, intermediation, property management and construction services, and 8.4% for leasing, onerous assignment and rental arrangements.

The reform raises the level of sophistication of tax controls and revenue collection: DIMOB and DOI are integrated with CIB (Brazilian Real Estate Registry), all connected to Sinter (National Territorial Information Management System). The result is a State with greater traceability and enhanced capacity to combat informality in the real estate market.

The reform requires a change in mindset, operational adjustments and strategic analysis of business activities, as the new tax structure will substantially impact the real estate sector as a whole.

Those who are not prepared may face operational and tax difficulties. Mapping operations, adjusting systems and training teams can turn the challenges of the transition into a competitive advantage.