Brazil's Tax Reform: What the Federal Revenue Service and SAP Have Delivered — and What Is Still Missing

As Brazil's tax reform moves forward, companies running SAP need to keep a close eye on what Brazil's Federal Revenue Service (Receita Federal do Brasil, RFB) and SAP have already delivered — and, above all, on what is still pending or has no delivery date.

The deadline is critical: by October, every company must have the changes implemented in its quality assurance environment (QAS), or risk being unable to issue invoices in the homologation (test) environment, which would affect ongoing projects.

We put together a direct comparison, updated with the latest status (July 2025), so you have a clear, objective view of what has been delivered, what has a planned release date, and what still has no defined dates:

✅ Brazil's Federal Revenue Service (RFB) – What has been delivered?

• March 2025: New fields created for the IBS (Tax on Goods and Services), CBS (Contribution on Goods and Services), and IS (Selective Tax) taxes
• June 2025:
• Delivery of additional fields, validation rules, and events for IBS and CBS assessment
• Release of the XSD file with the XML standards

🔄 Federal Revenue Service – What is still pending?

• Rules for changes to the DANFE (the printed summary of the NF-e, the Brazilian electronic invoice), with emphasis on the new requirements for displaying taxes
• Rules for IS (Selective Tax) validation and assessment
• Definition of the specific NCM (Mercosur Common Nomenclature) code for the IS
• Tax classification code applicable to the IS

📌 Important note: the QAS (quality) requirement becomes critical in October 2025.

✅ SAP – What has been delivered?

• NF-e: Adjusted so that the new taxes are neither posted nor added to the invoice total, for both purchases and sales
• Pricing: Full implementation of the IBS and CBS calculation logic
• Materials Management: Tax procedures adjusted
• NFWriter: Logistics adaptations to support the new taxes

In addition, between June 30 and July 5, SAP released:

• New tax attributes and determinations in the sales process, including:

• New fields, domains, and tables
• J1BTAX maintenance view for entering CBS and IBS rates
• Updated sales pricing
• Changes to the invoice bookkeeping tables to support the new rules in Technical Note (NT) 2025.002 v1.10
• Item category improvements for automatic determination of the tax situation code
• NBS (Brazilian Nomenclature of Services) determination for service purchases
• SAP has released the detailed scope via SAP Note.
• Adjustment to exclude PIS, COFINS (federal contributions levied on revenue), and ISS (municipal tax on services) from the IBS/CBS tax base when these taxes are included in the net price
• Applies to both materials and services

📅 SAP — Scheduled deliveries (with dates)

🔸 August 5, 2025 (confirmed forecast):

• Updated July 8: Net base according to the validation rule in NT 2025.002 v1.10, and invoice mapping for sales in foreign currency.

🔸 August 15, 2025 (confirmed forecast):

• Updated July 8: Updates and adjustments to tax determination in the sales process.

🔸 August 29, 2025 (confirmed forecast):

• Updated July 8: NBS determination for service sales scenarios.

🔸 September 12, 2025 (confirmed forecast):

• Updated July 8 – Sales – Brazilian tax groups included in net price conditions.
• The expected solution is to have the tax reform taxes calculated for sales of materials with PIS and COFINS included in the net price, and for sales of services with PIS, COFINS, and ISS included in the net price.

⏳ SAP — Items with no delivery date yet

• Subsequent deliveries in the Materials Management scenario
• Implementation of the IS (Selective Tax) in SAP

Conclusion and next steps

Both the Federal Revenue Service and SAP are delivering at a fast pace, but the time window is short and full of interdependencies.

The recommendation is clear: companies that have not yet started their implementation must act urgently. Those with projects already underway should closely track every SAP and RFB delivery to ensure compliance by the required deadlines.

Intellevo will stay at the forefront of tax changes in SAP systems and has already implemented these notes in its internal environment. This allows us to assess the impact and keep our customers informed to ensure a safe and efficient transition.

📩 Need expert support to speed up your SAP adaptation to Brazil's tax reform?

Intellevo is helping a number of customers diagnose, plan, and implement the changes in their ERP — from QAS to PRD.

👉 Get in touch.

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