After the National Meeting of Tax Coordinators and Administrators (Encat), that took place in March, in Teresina-PI, the Technical Note 2025.002 (Version 1.00) was released on the Electronic Invoice Portal, on March 28. The note replaces RT NT 2024.002 - IBS/CBS v1.10, which had been published on December 6, 2024 and was addressed by our tax team in a previous article.

The two technical notes address the creation of new fields and modifications of certain controls to adapt the layout of the Electronic Invoice (NF-e, models 55/65) and the Electronic Consumer Invoice (NFC-e).

The changes refer to the inclusion of specific fields for identifying and calculating the Tax on Goods and Services (IBS), the Contribution on Goods and Services (CBS) and the Selective Tax (IS).

Initially, the tests of the system and the adoption of the layout would take place starting September 1. The implementation was scheduled for October 31. Technical Note 2025.002 (Version 1.00), however, advanced the schedule and established that tests will begin on July 1st, jointly with implementation (production environment) scheduled for October 1st.

Among the events created, Technical Note 2025.002 (Version 1.00) addresses the following layout additions and modifications:

  • Validation rule referring to the calculation basis of the IBS and CBS, jointly with the identification of the items that form the value of the calculation basis of the IBS and CBS, in addition to the possibility of rejection, if this value does not correspond to the total of the components listed.
  • Inclusion of a specific event for the IBS group under the jurisdiction of the States, which allows the NF-e to be rejected when the gross value of the IBS tax due to each of the Federative Unit is calculated in an incorrect manner.
  • Identification of the municipality where the taxable event of the IBS occurs, with validation if the operation occurs with the presence of the parties but not at the establishment, indicating that rejection should occur, if the municipality is informed on operations that are not the ones listed.
  • List of events for IBS and CBS calculation, including, but not limited to:
    • "Request for Credit Appropriation for goods and services that depend on the acquirer's activity", jointly with the identification of specific amounts for the one issuer of the event ("Issuer Company", "Recipient Company", "Company", "Tax Authorities", "RFB", "Successor Company" and "Others").
    • "Manifestation on Request for Transfer of Credit of IBS [and CBS] in Succession Operations", to be generated by the successor in relation to the credit transfer invoices of another successor of the same succeeded, to inform the acceptance of the transfer.

The debit and credit notes are intended for IBS and CBS adjustments. By the debit note, the drawer registers an increase in the tax due, resulting in a decrease, reduction in the tax to be paid, paid-in by the acquirer, who is the addressee. On the other hand, by the credit note, the drawer registers a decrease in the tax due, leading to an increase in the tax to be paid, paid-in by the acquirer, who is the addressee.

Regarding these two notes, Technical Note 2025.002 (Version 1.00) clarifies that "in intercompany transactions, the supplier can charge a fine and interest from the customer and the IBS and CBS are levied are levied over such amounts. The customer when paying this additional amount can register a credit of the tax paid. In this situation, a note can be issued with the arrangement of interests and fines. The collection of interests and fines can come from late payment of the bank slip, without the issuance of a note for the interest and fines. In this situation, there must be an Event for the acquirer to guarantee the additional credit, generating a debit for the other taxpayer."

In addition to the technical note analyzed above, we highlight that, on March 31, Resolution CGNFS-E 5/25 was published, which establishes the public-private Technical Working Group (GT-NFS-e), to collaborate in the development and improvement of the Electronic Services Invoice (NFS-e).

The GT-NFS-e aims to establish a forum for continuous technical dialogue for the construction, maintenance and evolution of the NFS-e, in order to meet the needs of the Federal Revenue Service of Brazil (RFB), the municipalities and the Federal District.

The GT-NFS-e will consist of:

  • representatives of the RFB;
  • representatives of the municipalities and the Federal District; and
  • representatives of companies that develop solutions for the issuance of tax documents and representative entities, appointed by the municipalities and the Federal District or that have signed terms of cooperation technique jointly with RFB.

The composition of the GT-NFS-e will be permanent and with an indefinite duration. The working group will act as a consultive and non-binding forum, aiming to foster debates and evaluations on solutions for the evolution of NFS-e.

The GT-NFS-e will hold periodic meetings, the frequency of which will be defined jointly by its members, and may create sub-task groups to address specific topics.

The Executive Secretariat of the CGNFS-e will be responsible for managing the GT-NFS-e, including the definition and control of the number of participants, to ensure its proper functioning.

In addition, the secretariat will enroll the representatives appointed by the members of the task group, coordinate the activities and organize the meetings, which may be held in person or virtually.

Our tax team remains available to answer any questions on the subject.