Foreign SaaS Providers Under Brazil’s CBS and IBS: Registration, Liability and Collection

For years, a foreign software company selling subscriptions to Brazilian customers mostly left Brazilian taxes to its customers: the business buyer withheld income tax and paid the import contributions when remitting payment, and consumers paying by card were rarely taxed at all. The consumption tax reform changes that. Under the new CBS (federal) and IBS (state and municipal) taxes, foreign suppliers of services and intangibles, including SaaS and digital services, are brought into the system, with registration duties, joint liability and collection at the point of payment. This guide explains the rules as they stand in October 2026 and what a foreign provider should prepare for before 2027.

When a foreign sale is an “import” for CBS and IBS

Under Complementary Law 214/2025, a supply of services or intangible goods by a resident abroad is an import, and taxable in Brazil, when it is consumed in Brazil (article 64). Since the amendments of Complementary Law 227/2026, consumption in Brazil means that either the place of supply defined by the law is in Brazil, or, in the remaining cases, the buyer or the recipient is domiciled in Brazil. If a service is consumed partly in Brazil and partly abroad, only the Brazilian portion is taxed.

For a typical SaaS subscription bought by a Brazilian company or individual for use in Brazil, the supply will be an import. The rate is the same as for a domestic supply of the same service.

Who pays: the buyer, with the foreign supplier jointly liable

The law does not create separate B2B and B2C regimes: the buyer is always the taxpayer. The practical difference is collection. A Brazilian business under the regular regime pays and credits the tax; an individual consumer is unlikely to do so, which is why the law relies on the supplier’s joint liability, the platforms and the payment chain.

Selling only through a platform

A foreign supplier that sells to Brazil exclusively through digital platforms registered in the regular regime does not need to register itself (article 22). The platform takes on the responsibility. Payment institutions authorized by the Central Bank and advertising services are not treated as platforms for this purpose.

Registration: a CNPJ, not a separate simplified regime

Despite references in some commentary to a “simplified registration” for non-residents, the law and the CBS regulation provide for registration in the national taxpayer register (CNPJ), in the regular regime, with a single identification for CBS and IBS. The CBS regulation, Decree 12,955/2026, published on April 30, 2026, expressly covers platforms domiciled abroad. Its registration chapter applies from the first day of the fourth month after publication, which points to August 1, 2026.

Failing to register within the deadline carries a fine of 10 UPF (the federal fiscal unit used for the new taxes), under the penalty rules added by Complementary Law 227/2026. The rules for issuing tax documents on imports of services, including the reference to the foreign exchange contract, depend on a joint act of the Federal Revenue and the IBS Management Committee.

Collection at the point of payment

When the foreign supplier or platform is not registered, the institution that carries out the foreign exchange for the payment must separate and pay CBS and IBS at the reference rates on the amount remitted. If the rate that actually applies to the service is higher, the Brazilian buyer pays the difference; if lower, the buyer can recover it. The detailed criteria depend on a joint act of the Federal Revenue and the IBS Management Committee.

Separately, the reform’s split payment mechanism, under which payment providers separate the tax at the moment of payment, is being phased in; platforms that initiate payments must provide the information needed for it once it is available. Its operating date for each type of transaction is still to be defined.

The timeline

The CBS rate for 2027 had not been fixed by October 2026. The law sets a ceiling mechanism: if the combined reference rates estimated for 2033 exceed 26.5%, the government must propose measures to reduce them. Government estimates of the combined rate have ranged around that figure, and should be treated as estimates.

Other taxes on the remittance, such as withholding income tax and, where applicable, CIDE and IOF, are not part of the consumption tax reform and continue to apply to payments abroad.

What a foreign SaaS provider should do now

1. Map Brazilian revenue by channel: direct contracts with businesses, direct card sales to individuals, and sales through app stores or marketplaces.
2. Decide on registration. Selling only through registered platforms may avoid it; direct sales point to a CNPJ registration and Brazilian reporting.
3. Review contracts and pricing with business customers, who will pay CBS and IBS on imports and expect correct documentation to take credits.
4. Prepare billing systems for Brazilian tax data, documents and the foreign exchange reference, as the joint acts are published.
5. Consider a local entity if Brazilian revenue is material: a Brazilian subsidiary invoices domestically, takes credits and avoids remittance taxes on each sale, but brings its own compliance (see technology and SaaS companies in Brazil).

How Solidy can help

Solidy already serves subsidiaries of multinational companies in Brazil, including technology companies. Our tax team maps how CBS and IBS apply to your Brazilian sales, supports registration and reporting, and models the alternative of operating through a Brazilian entity. Read Brazil’s tax reform explained for foreign headquarters or talk to our specialists.