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Brazil: Complementary Law No. 227/2026 Formally Establishes the IBS Management Committee and Advances Tax Reform Operationalization

Barbara Carvalho
January 15, 2026

On January 13, 2026, Complementary Law No. 227/2026 was published, formally establishing the Management Committee of the Goods and Services Tax (CGIBS) and regulating key aspects of the governance, administration, and administrative tax litigation framework for IBS under Brazil’s Tax Reform.

The new law represents a major structural milestone by moving IBS from a constitutional concept to a fully defined institutional model, with clear rules for governance, intergovernmental coordination, and revenue distribution between states and municipalities.

Establishment of the IBS Management Committee (CGIBS)

Complementary Law No. 227/2026 formally establishes the CGIBS as the body responsible for the administration, collection, auditing, and distribution of IBS, through an unprecedented cooperative arrangement among federal, state, and municipal tax authorities.

The Committee will act as the central operational authority of the new tax, effectively replacing the fragmented administrative models currently used for ICMS and ISS, which will be gradually phased out during the transition period.

Administrative tax litigation and revenue distribution

In addition to IBS governance, the law also regulates:

  • The administrative tax litigation framework for IBS, with specific rules for dispute resolution;

  • Revenue distribution criteria among states, municipalities, and the Federal District;

  • Coordination and standardization mechanisms, designed to ensure uniform application of IBS across the country.

These elements are critical to reducing regional disparities and increasing legal certainty under the new tax system.

Impact on businesses

Although Complementary Law No. 227/2026 does not impose immediate new obligations on taxpayers, it confirms that IBS will operate under a centralized, standardized, and highly coordinated administrative model, with direct implications for audits, enforcement, and data cross-checking in the future.

For businesses, this reinforces the need to:

  • Prepare systems and processes for a national tax administration model with reduced fragmentation;

  • Ensure data consistency and quality, particularly across electronic tax documents;

  • Anticipate technology adjustments to support new audit, reporting, and dispute management workflows.

The publication of this law confirms 2026 as a critical year for structural preparation, in which decisions related to tax governance, data architecture, and technology become strategic to mitigate long-term compliance risks throughout the transition period.

Source: Diário Oficial da União – Lei Complementar nº 227, de 13 de janeiro de 2026

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Author

Barbara Carvalho

Bárbara Pereira de Carvalho ingressou na Sovos em 2020 e atua como Regulatory Counsel no Brasil. É formada em Direito e possui pós-graduação em Direito Tributário, com experiência na área de tributação e regulação fiscal no contexto brasileiro.
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