Taxable Persons of IBS and CBS

Brazil’s Constitutional Amendment No. 132/2023 introduced a dual consumption tax system based on two closely coordinated taxes: the tax on goods and services (imposto sobre bens e serviços, IBS) and the contribution on goods and services (contribuição sobre bens e serviços, CBS). Although levied by different levels of government, IBS and CBS are subject to common rules on taxable events, tax base, credits, and taxable persons. In this article, the authors examine the persons and entities that may be required to comply with IBS and CBS obligations. They discuss the ordinary taxpayer, liable parties, substitute taxpayers, jointly and severally liable parties, persons excluded from taxpayer status, digital platforms, the unified registration system, cashback, and the specific rules applicable to import transactions.