IBS, CBS, and the Accounting Challenges of the Transition Period
The publication of CFC Technical Guidance No. 01/2026 represents one of the first institutional efforts aimed at interpreting the accounting impacts resulting from the entry into force of the IBS and the CBS, as well as the challenges associated with the 2026 operational testing period. Although the document is intended for accounting professionals, its implications extend to much broader areas within organizations, including finance, internal controls, billing, technology, tax compliance, and contract management.
Rather than offering definitive answers, the Guidance draws attention to issues that are already on the agenda of business leaders, CFOs, controllers, administrative directors, and advisors during this transition period.
Perhaps the main message is precisely this: Tax Reform requires more than just fiscal adjustments. It already calls for accounting adjustments, a review of processes, and new control procedures.
IBS and CBS are not included in the entity’s accounting revenue
One of the key points of the Guidance is the understanding that IBS and CBS are taxes levied “externally” and collected by the taxpayer on behalf of the State. For this reason, the amounts set aside for this purpose are not included in the entity’s revenue and must be recorded in specific balance sheet accounts.
Based on this logic:
- Revenue corresponds only to the consideration actually due to the company;
- The taxes shown represent amounts due to the tax authorities;
- Therefore, these amounts should not be included in revenue recognized for accounting purposes.
This conclusion is also consistent with CPC 47 and IFRS 15, accounting standards that address revenue recognition and are based on the premise that amounts collected on behalf of third parties are not included in the entity’s revenue.
For many companies, especially service providers, this may be the most relevant and immediate takeaway from the Guidance.
Does the discussion end with accounting?
Not necessarily.
This accounting conclusion, however, raises an additional question: Would it be possible to draw conclusions from it regarding other taxes?
Based on this understanding, there is room to discuss the potential implications of this accounting treatment on certain concepts of gross revenue used in tax law.
This is a relevant discussion, especially for taxpayers subject to tax regimes based on gross revenue. However, it is important to note that the CFC Guidance is of an accounting nature and does not, in and of itself, alter:
- Complementary Law No. 214/2025;
- IRPJ legislation;
- the CSLL legislation;
- CPRB legislation;
- nor any other tax system currently in effect.
For this reason, it seems prudent to distinguish between two issues.
What seems to be relatively well established
The understanding that IBS and CBS are not included in the entity’s accounting revenue.
What is still evolving
The potential tax implications arising from this interpretation.
This debate will still depend on the consolidation of administrative interpretations and, possibly, the development of judicial precedents on the matter.
Accrual Basis and Cash Basis: A Coexistence That May Become More Complex
Another point worth noting is the Guidance’s reaffirmation that the accounting recognition of IBS and CBS must follow the accrual basis of accounting.
This means that the accounting effects of the new taxes must be recognized when the transaction giving rise to them occurs, regardless of when the actual payment or receipt takes place.
This point may be particularly relevant for legal entities that:
- calculate IRPJ and CSLL based on presumed income;
- use the cash basis for tax purposes;
- have long accounts receivable cycles.
The Guidance does not change the method for calculating these taxes. However, it highlights that accounting, taxation, and cash flow may follow different logics, requiring more sophisticated internal controls to reconcile this information.
In practice, many companies today face the need to balance:
- an accrual-based accounting approach;
- a fiscal approach that may be based on a cash basis;
- a financial reality determined by actual receipts and payments.
Tax credits are taking on a strategic role
The Guidance also stipulates that IBS and CBS credits generated from acquisitions must be recognized for accounting purposes as recoverable assets, provided that the recognition requirements set forth in the accounting standards are met.
This guideline underscores the importance of tax credit management in the new system.
In practice, companies have been required to develop controls capable of:
- identify eligible credits;
- link credits to the corresponding transactions;
- monitor credits subject to subsequent validation;
- track credits recorded in the accounting records and credits recognized for tax purposes;
- maintain documentation sufficient to support any audit.
For many organizations, this is already one of the biggest operational challenges resulting from the tax reform.
Split payment changes more than it seems
Another issue highlighted by the Guidance is split payment, a mechanism whereby financial institutions or payment intermediaries will now allow for the automatic segregation of the portion corresponding to the IBS and CBS at the time of the transaction’s financial settlement.
Although the debate is often associated with tax collection, its effects are much broader.
The new model already requires companies to assess direct impacts on:
- revenue;
- accounts receivable;
- bank reconciliations;
- ERP;
- financial controls;
- operating cash flow.
In practical terms, the amount actually received by the company may be less than the nominal value of the transaction, requiring new reconciliation procedures and new assumptions for financial projections.
For this reason, adapting to the split payment system involves not only tax considerations but also a review of operational processes and financial governance.
A Little-Explored Topic: Expense Reimbursements
One of the most interesting points in the Guidelines may well be a topic that is touched upon indirectly throughout the document.
By stating that amounts collected on behalf of third parties are not considered part of the entity’s revenue, the Guidance reinforces a principle already present in the IBS and CBS legislation, according to which certain refunds or reimbursements related to transactions carried out on behalf of or at the direction of third parties may be treated differently from the entity’s own revenue.
In this context, an important point arises.
Let’s consider, for example, situations involving:
- costs and fees;
- notary fees;
- shipping and logistics costs reimbursed;
- travel and lodging expenses paid on behalf of clients;
- advance payments for the purchase of goods or the procurement of services on behalf of third parties;
- administrative expenses that were subsequently reimbursed.
To what extent do these amounts represent the entity’s own revenue? In what situations do they constitute merely reimbursement for expenses incurred on behalf of third parties?
Similar disputes may arise in various sectors of the economy, especially when an entity makes payments on behalf of third parties or subsequently recovers amounts paid in advance in the course of its activities.
The Guidance does not go into detail on these specific situations nor does it establish criteria for analyzing them.
However, the conceptual framework adopted by the document may fuel future discussions regarding the accounting and tax treatment of refunds, a topic relevant to various business models and sectors of the economy.
2026: A Year of Testing or a Year of Taxation?
One of the most important chapters of the Guidelines addresses the current IBS and CBS testing period, which is underway during fiscal year 2026.
According to Legislative Decree No. 214/2025, the 2026 trial period requires the calculation of the IBS and CBS and compliance with the respective ancillary obligations, alongside rules exempting compliant taxpayers from payment, as well as mechanisms for offsetting or reimbursing any amounts that may have been paid.
This scenario raises an important technical question:
Should taxes be recognized for accounting purposes in 2026 or not?
The Guidance itself presents arguments for both positions.
After all, what is the legal nature of the exemption from payment in 2026?
The debate stems from the wording of LC No. 214/2025 itself.
A first reading suggests that:
- Taxes arise naturally;
- the triggering event occurs;
- the tax rates exist;
- The exemption is merely a benefit contingent upon compliance with ancillary obligations.
Under this view, a tax liability would initially exist, but would subsequently be offset due to the statutory exemption.
A second interpretation holds that:
- The 2026 goal is primarily operational;
- The legislature’s purpose is not to raise revenue;
- Compliance with ancillary obligations is an integral part of the design of the trial period;
- There is no substantial financial obligation for the taxpayer in good standing.
This difference in interpretation has significant practical implications for the accounting recognition of IBS and CBS during 2026.
What exactly will companies have to decide?
Although the debate is technical, its consequences are quite concrete.
Goal 1: Recognize IBS and CBS by 2026
Proponents of this school of thought believe that:
- the taxable transaction actually took place;
- the taxable event has occurred;
- There is a legally established tax liability.
From this perspective, the entity would record:
- IBS/CBS debits;
- IBS/CBS credits;
- any potential tax liability;
and would subsequently recognize the termination of that obligation due to the statutory exemption.
Position 2: Do not recognize IBS and CBS in 2026
Proponents of the second school of thought argue that:
- there is no realistic economic expectation of an outlay;
- the law itself sets aside the economic effects of the tax;
- The exemption is part of the testing system’s structure.
In that case:
- the figures would be calculated for informational purposes;
- internal controls would be maintained;
- but there would be no recognition of the tax as an asset.
The most important point: the CFC did not choose a single answer
Perhaps the main message of the Guidance lies precisely here.
The Federal Accounting Council expressly acknowledged the existence of a technical controversy and chose not to impose a uniform solution on all taxpayers.
Instead, item 30 of the Guidance recommends:
- an individual assessment of the entity’s circumstances;
- documentation supporting the position taken;
- transparent disclosure of the chosen accounting policy;
- Maintenance of adequate internal controls for IBS and CBS throughout 2026.
The message is clear:
More important than the position chosen is the ability to technically demonstrate the rationale behind that choice.
What does that mean in practice?
Regardless of the position taken, every entity subject to the IBS and CBS will need to have a formally defined accounting policy in place for the trial period by the end of 2026.
In other words:
- The discussion is not merely academic;
- This issue cannot be ignored;
- The policy adopted must be documented;
- The decision will need to be properly disclosed in the financial statements.
How has this issue been addressed in practice?
The observations made so far often describe 2026 as a period focused primarily on operations and information, emphasizing:
- exemption from payment;
- compliance with ancillary obligations;
- the absence of any actual financial impact on taxpayers who are up to date with their payments.
This does not mean, however, that there is a consensus regarding the accounting implications resulting from this exemption.
The CFC’s Guidance itself shows that the matter remains open to more than one technically defensible interpretation.
What should companies be monitoring right now?
Regardless of the accounting treatment each company may adopt, the publication of the Guidance suggests some issues that warrant close monitoring:
- adaptation of systems for IBS and CBS;
- preparation for split payment;
- development of tax credit controls;
- establishment of the accounting policy applicable to fiscal year 2026;
- processing of refunds and amounts collected on behalf of third parties;
- the coexistence of the accrual basis and the cash basis;
- future statements by the Federal Revenue Service, the IBS Management Committee, and the CFC itself.
Concluding Remarks
CFC Technical Guidance No. 01/2026 is not intended to put an end to the debates surrounding tax reform. On the contrary, it highlights that several relevant issues are still in the process of being fully developed.
The document confirms that IBS and CBS should be treated for accounting purposes as taxes collected on behalf of the State and not as the entity’s own revenue. At the same time, it opens up important discussions regarding:
- the boundaries between accounting and taxation;
- the management of tax credits;
- the operational effects of split payment;
- reimbursement of expenses;
- the legal nature of the exemption from payment in 2026;
- the accounting policy to be adopted during the testing period.
Finally, the publication also reinforces existing discussions regarding the possible implications of the accounting treatment of the IBS and the CBS on other taxes and tax calculation regimes. Although some of these interpretations are based on sound legal grounds, it seems premature to treat them as definitively settled issues, especially given the absence of specific administrative or judicial rulings on the matter.
In the context of our first year of practical experience with the IBS and the CBS, perhaps the main lesson from Orientation is this:
Adapting to the tax reform will require more than just the correct payment of taxes. It will also require sound accounting decisions, well-documented processes, and internal controls capable of supporting the choices made by companies.