Supplementary Law No. 214/2025 represents a milestone in the Brazilian tax reform by introducing the Dual VAT (IBS/CBS) and the Selective Tax, the latter still subject to specific regulatory measures for the definition of applicable rates. The implementation of this new legislation will bring significant challenges and opportunities for businesses and taxpayers, requiring a thorough analysis of the approved provisions and, most importantly, the vetoes issued by the Executive Branch on Complementary Bill No. 68/2024.
In this document, we present a technical and detailed analysis of the vetoes applied, examining their foundations, practical implications, and potential outcomes. The structure follows the order in which the vetoes were introduced, providing a clear and objective view of the necessary changes and adjustments to adapt to the new tax landscape.
The tax reform will require strategic actions and operational adjustments to ensure compliance and efficiency. Our Tax Law Team is ready to assist your organization in every step of this process, from impact assessments to the implementation of strategies for tax optimization.
Access the sections “Transition and Next Steps” and “How We Can Help” to gain a better understanding of the timeline of changes and the solutions we can offer.
Table of Contents
Vetoes 1 to 21
- 1 to 5 – Funds
- Veto 6 – Joint liability of the purchaser
- Veto 7 – Ending of deferral in operations with rural producers who are not contributors of IBS and CBS
- Veto 8 – Zero rate on the import of financial services
- Veto 9 – Real estate transactions
- Vetoes 10 and 11 – Electronic Tax Domicile (DTE)
- Veto 12 – Exemption of mineral exports from the Selective Tax
- Veto 13 – Fine calculated on the value of the IS levied on tobacco
- Veto s 14 and 15 – Presumed IBS credit on imports for resale in the ZFM and ALC
- Veto 16 – Presumed CBS credit for products with zero IPI rate, produced in the ZFM
- Veto 17 – Review of differentiated, special and specific regimes
- Vetoes 18 and 19 – Recreation of ESAF
- Veto 20 – Tax substitution in Simples Nacional
- Veto 21 – Services linked to sovereignty and national security
