By Vottax at 01 de Outubro de 2025

Between September 29 and 30, 2025, Brazil’s Senate approved the second stage of the Tax Reform’s regulation (PLP 108/2024), establishing rules for the IBS Management Committee and detailing governance, collection, enforcement, and revenue sharing; because amendments were made, the bill now returns to the House for final review.. The IBS Committee will be a special public entity with technical, administrative, budgetary, and financial autonomy, responsible for operating IBS collection and allocation among states and municipalities during the transition that replaces ICMS and ISS with the dual VAT (IBS/CBS) by 2033..

 The bill confirms the coexistence of legacy and new taxes, sets mechanisms to calibrate rates using 2024–2026 baselines, and defines implementation steps and governance with oversight by audit courts.

Regarding enforcement and disputes, the text provides a pedagogical approach during part of the transition (time to correct omissions), unifies penalties for ancillary obligations with reductions where there is no fraud, and increases fines for evasion and repeat offenses; it also creates the National Chamber for Administrative Tax Disputes Integration for IBS and CBS to harmonize precedents and handle electronic appeals. On funding, the Federal Government will cover setup costs for the Committee until 2028; thereafter, financing will come from IBS revenue percentages through 2032, with transparency and periodic reports; the bill also addresses accumulated ICMS credits in the transition to IBS, allowing offsetting, transfer, and reimbursement in installments, with conditional early redemption tied to IBS revenue performance.

 With Senate approval and the incorporated updates, the proposal returns to the House before complementary infra-legal regulations and the definition of reference rates by a Senate resolution.

 

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