Brazil's Ministry of Finance is sending a complementary bill to Congress giving companies 30 additional days to finalize their CBS tax settlement in 2027—the first year the new federal tax replaces PIS and Cofins. The move does not delay the start of the tax reform; instead, it establishes a two-step payment process so companies are not forced to pay the tax before confirming the tax credits they are owed.
Why Companies Cannot Pay CBS on the Standard Deadline in 2027
The problem is technical, but it carries a direct financial cost. Under the current PIS and Cofins regime, the issued invoice automatically guarantees the buyer's tax credit. A company acquiring an input can deduct the tax amount immediately, regardless of whether the supplier has remitted a single cent. With CBS, that logic changes: the credit is only released after the supplier effectively pays the new tax. For the buyer, this means the right to the discount remains pending until the supply chain above them closes its figures.
Without the extra time, the calendar would create a liquidity trap right in the first quarter. A company would make its sales and purchases in January and have to remit CBS as early as February—yet January credits would not yet be confirmed, as they depend on supplier remittances. Paying gross tax before deducting credits is not merely an accounting inconvenience; it means tying up advance working capital that may not be available, especially in sectors with narrow margins or long receivables cycles.
The proposal resolves precisely this mismatch. And why must it pass through Congress as a complementary bill rather than an internal ruling from the Federal Revenue? Robinson Barreirinhas, Special Secretary of the Federal Revenue, was precise.
"It is not just a change in collection deadlines. We are changing the calculation methodology defined in the complementary bill."Robinson Barreirinhas, Special Secretary of the Federal Revenue, Nov 11, 2026
How the Two-Step Collection Will Work
The rule will apply only in 2027. Collection will take place in two stages: in the month following operations, the company pays an estimated CBS amount; in the subsequent month, it makes a final settlement based on credits already confirmed throughout the supplier chain.
The model resembles the monthly estimated corporate income tax (IRPJ) familiar to companies under the actual profit regime (Lucro Real): an advance payment followed by adjustments when final figures become clear. For 2027, companies may also opt for Acquirer Collection (RAD) as an alternative while split payment is not yet fully operational. The proposal is not guaranteed, however: Congress must approve it as a complementary bill before January for the new calendar to take effect on day one of CBS—and any delay in the legislative process eliminates the adaptation window.
The CBS Rate Is Not Yet Finalized—Deadline Is December 15
In October, the Federal Court of Accounts (TCU) calculated the reference CBS rate at 11.3468%, rounded to 11.3%. This figure still needs to be made official via a Federal Senate resolution by December 15, 2026. Until the vote takes place, the rate remains provisional—and the Senate debate is far from over, as shown by Senator Eduardo Braga's rejection of the 11.3% calculation in November. Braga is the Senate rapporteur for the reform.
The actual rate charged in practice in 2027 and 2028 will be 11.2%—0.1 percentage point below the 11.3% reference—because the IBS (the reform's state-municipal tax) remains in a testing phase at 0.1% during those first two years, and this difference is discounted from CBS to keep the overall tax burden equivalent. The increase from 9.25% to 11.2% does not represent a tax hike in all cases. For companies under Lucro Real with long chains of taxable inputs, the CBS credit base is broader than current PIS/Cofins rules permit, which can offset the difference. Conversely, companies under the presumed profit regime (Lucro Presumido) that currently remit cumulative PIS and Cofins at a 3.65% rate without credits face a more significant change on paper—though the newly permitted deduction of inputs could reduce the net impact depending on the sector.
Split Payment Solves the Problem—But Launches Only in August
The definitive solution to the mismatch between payments and credits is split payment: a mechanism where financial institutions automatically withhold and remit CBS at the moment B2B payments occur. With this system, the tax is paid at the time of the transaction and the credit becomes immediately available to the buyer, eliminating the confirmation-order problem that necessitates an extra window in 2027. The mechanism was regulated by Complementary Law 214/2025, adjusted by Complementary Law 227/2026, and entered a non-collection testing phase on October 15, 2026, with participation from major payment networks. In 2027, the mechanism will be optional for B2B transactions, with the Federal Revenue projecting full operation starting in August.
Until August 2027, therefore, the two-step proposal under discussion will apply. The risk of delay is real: split payment depends on the technical integration of all payment arrangements—credit cards, bank slips (boletos), Pix—and any slip extends the two-step system beyond 2027. Senator Flávio Bolsonaro's proposal to scrap split payment and the resulting clash with the Ministry of Finance demonstrate that the mechanism lacks unanimous backing in Congress, adding uncertainty to the timeline. The National Confederation of Industry (CNI) even sent a letter to the Ministry of Finance asking for 2027 to function entirely as a testing period without full collection—a request rejected by the government, which is maintaining the January launch for CBS while acknowledging the need for targeted adjustments such as the extended deadline.
The debate over the reform's scope extends beyond payment deadlines. Flávio Bolsonaro's proposal in October for a broad overhaul of the tax reform and the financial market's reaction indicate that the political environment surrounding implementation remains fluid—and any legislative approval, including the extra CBS window, must navigate a Congress with divergent views on the pace of the transition.
The immediate risk is cash flow, not tax rates. The Ministry of Finance's proposal cushions liquidity pressure in the first quarter of 2027: without it, companies in narrow-margin sectors—retail, services, homebuilders—could start the year with higher-than-expected cash outflows before confirming their credits. With the two-step system approved, the impact is diluted. Unresolved issues include the definitive rate (subject to a Senate vote by December 15), the passage of the complementary bill itself, and the actual launch date for split payment, which the Federal Revenue projects for August but depends on financial market adoption. Service- and labor-intensive companies lacking long credit chains will be the most exposed to the nominal increase from 9.25% to 11.2%.
Passage of the complementary bill in Congress — must be signed into law before January; without it, the two-step schedule does not exist, and companies must pay CBS in the month following operations without a settlement period and with unconfirmed credits.
Senate vote on the tax rate by December 15 — the resolution setting CBS at 11.2% requires approval; if the deadline passes, the 11.3% TCU reference serves as a provisional baseline, introducing uncertainty into early 2027 financial statements.
Split payment fully operational starting in August 2027 — date confirmed by the Federal Revenue; if delays occur due to lagging payment integration, the two-step system will be extended; monitor: RFB and Central Bank announcements regarding the testing phase.
