The publication of Technical Guidance No. 01/2026 by Brazil's Federal Accounting Council (CFC) marks an important step in clarifying the accounting implications of the implementation of the Goods and Services Tax (IBS)and the Contribution on Goods and Services (CBS) under Brazil's Tax Reform.
Although primarily addressed to accounting professionals, the Guidance extends well beyond the accounting function. Businesses will need to review internal processes, strengthen controls, and coordinate efforts across finance, compliance, technology, billing, and corporate governance to address the new requirements introduced by the Tax Reform.
More than providing technical guidance, the document highlights that adapting to the new tax system requires strategic planning and informed accounting decisions throughout the transition period.
IBS and CBS Are Not Part of a Company's Revenue
One of the Guidance's key conclusions is that IBS and CBS should be treated as taxes collected on behalf of the government rather than as part of a company's own revenue.
Accordingly, the amounts collected should be recorded in specific balance sheet accounts, consistent with CPC 47 and IFRS 15, which establish that amounts collected on behalf of third parties do not constitute revenue.
In practice, this means that only the consideration effectively earned by the company should be recognized as accounting revenue.
This interpretation is expected to have a significant impact, particularly on service providers.
Tax Credits and Split Payment Take Center Stage
The Guidance also reinforces that IBS and CBS tax credits may be recognized as recoverable assets, provided the applicable accounting recognition criteria are met.
As a result, companies will need robust internal controls to identify eligible tax credits, monitor their utilization, and maintain adequate supporting documentation.
Another important topic is the split payment mechanism, which will allow the portion corresponding to IBS and CBS to be automatically separated at the time of financial settlement.
Although commonly associated with tax collection, split payment will also affect operational processes such as billing, accounts receivable, bank reconciliations, cash flow management, and ERP configurations, requiring companies to review existing financial and operational procedures.
The 2026 Transition Period Still Raises Accounting Questions
The Guidance also addresses one of the most significant issues surrounding the Tax Reform: the accounting treatment of IBS and CBS during the 2026 testing period.
While Complementary Law No. 214/2025 establishes the legal framework for this transition, different interpretations remain regarding whether these taxes should be recognized in the financial statements during the period in which compliant taxpayers are exempt from payment.
Rather than imposing a single accounting approach, the CFC recommends that each company evaluate its specific circumstances, formally document the rationale supporting its chosen accounting policy, and maintain internal controls consistent with that decision.
The Guidance emphasizes that the strength of a company's technical justification is more important than adopting one particular interpretation over another.
What Companies Should Be Monitoring
Regardless of the accounting policy ultimately adopted, the Guidance highlights several areas that deserve immediate attention:
- adapting systems to accommodate IBS and CBS;
- preparing for the implementation of split payment;
- strengthening tax credit controls;
- defining the accounting policy for the transition period;
- reviewing internal processes; and
- monitoring future regulations issued by the Brazilian Federal Revenue Service, the IBS Management Committee, and the Federal Accounting Council.
Addressing these matters proactively can help reduce operational risks and facilitate compliance with the new regulatory framework.
Technical Guidance No. 01/2026 represents an important milestone in shaping the accounting framework that will support Brazil's Tax Reform.
Although several issues still depend on further regulation and the consolidation of administrative interpretations, the Guidance makes it clear that implementing IBS and CBS will require far more than the correct calculation of taxes. Companies will need to review internal processes, strengthen governance, establish consistent accounting policies, and promote greater integration across strategic business areas.
Mourão Campos Group continuously monitors the evolution of Brazil's Tax Reform and its regulatory developments, assisting domestic and international organizations in assessing the accounting, tax, corporate, and operational impacts arising from the implementation of IBS and CBS. Through an integrated and multidisciplinary approach, the professionals of Mourão Campos Group support companies in preparing for this transition with confidence and regulatory alignment.
