On December 23, 2025, Joint Normative Act RFB/CGIBS No. 1/2025 was published in the Federal Official Gazette, providing the list of fiscal documents to be recognized by the Goods and Services Tax (IBS) and Goods and Services Contribution (CBS) regulations, as well as establishing the timeline for their fullfilment during 2026.
Among the existing fiscal documents recognized for recording transactions subject to the Dual VAT, we highlight the following:
- Electronic Tax Invoice (Nota Fiscal Eletrônica– NF-e), model 55;
- Electronic Services Tax Invoice (Nota Fiscal de Serviços Eletrônica– NFS-e);
- Electronic Electric Energy Invoice (Nota Fiscal de Energia Elétrica Eletrônica– NF3e), model 66;
- Electronic Communications Services Invoice (Nota Fiscal Fatura de Serviços de Comunicação Eletrônica– NFCom), model 62;
- Electronic Toll Road Services Invoice (Nota Fiscal de Serviço Eletrônica de Exploração de Via– NFS-e Via).
In addition, new fiscal documents were also created, as follows:
- Electronic Water and Sanitation Invoice (Nota Fiscal de Água e Saneamento Eletrônica– NFAg), model 75;
- Declaration of Specific Regimes (Declaração de Regimes Específicos– DeRE);
- Electronic Real Estate Alienation Invoice (Nota Fiscal Eletrônica de Alienação de Bens Imóveis– NF-e ABI), model 77; and
- Electronic Gas Invoice (Nota Fiscal Eletrônica do Gás– NFGas), model 76.
Finally, the act further provides that, until the first day of the fourth month following the publication of the general provisions of the IBS and CBS regulations, 1 no penalties shall apply for failure to complete the IBS and CBS fields, and the requirement for the exemption from payment of IBS and CBS shall be deemed automatically satisfied.
The Tax practice of Tauil & Chequer Advogados in association with Mayer Brown is available to provide further clarifications on this subject.
Footnote
1 These regulations are still being drafted, as explained ina news release by the Ministry of Finance.
Visit us at mayerbrown.com
Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.
© Copyright 2025. The Mayer Brown Practices. All rights reserved.
This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.
