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Briefing document & Podcasts: E-Invoicing & E-Reporting in Brazil

SUMMARY

Brazil has a mature and comprehensive electronic invoicing (e-invoicing) framework that operates on a continuous transaction control (clearance) model. It is mandatory for nearly all businesses and transactions, including B2B, B2C, B2G, domestic, import, and export. Invoices must be pre-approved in real time by tax authorities. The system leverages standardized XML documents (NF-e, NFS-e, etc.) and imposes strict penalties for non-compliance, including fines up to 100% of the invoice value. While currently taxpayers manually consolidate invoice data in monthly SPED reports and tax declarations, the upcoming 2026 tax reform aims to leverage e-invoice data for automated tax calculation and pre-populated tax returns. Recent adjustments have standardized the minimum retention period for electronic tax documents to 11 years.

Key Themes and Ideas:

Mandatory and Comprehensive E-Invoicing:

  • E-invoicing has been mandatory for “all businesses in Brazil that issue invoices” since 2008 for many taxpayers, with phased rollout for different sectors and transaction types.
  • “Virtually all invoiced transactions in Brazil fall under the e‑invoicing mandate,” encompassing B2B, B2C, B2G, domestic, import, and export transactions.
  • “Brazil’s mandate isn’t limited to B2B: any taxable sale to any customer must be electronically invoiced.”
  • The system covers various document types, including NF-e (goods), NFC-e (consumer), NFS-e (services), CT-e (freight), and others. “The mandate covers domestic transactions of all types and ensures that even traditionally paper-based or summary-billed sectors (transportation, utilities, telecom) use e‑invoices.”
  • A National NFS-e system, which becomes mandatory countrywide on January 1, 2026, will unify service invoices currently managed by each municipality.
  • The NFCom (Nota Fiscal de Serviços de Comunicação) for telecommunications services will be mandatory as of November 1, 2025, replacing after-the-fact reporting with real-time invoicing.
  • “Once the official go-live date arrives, compliance is expected immediately (there is generally no extended “grace period” after the mandate’s effective date).”

Real-Time Clearance Model:

  • Brazil operates on a “continuous transaction control (clearance) model,” requiring invoices to be pre-approved by tax authorities before the transaction is complete.
  • “Data is transmitted at issuance (no post-issuance grace period in general).”
  • For NF-e, the process involves generating the XML, submitting it to SEFAZ, and receiving an authorization response before shipping goods.
  • “The “due date” for transmission is concurrent with issuance; if you don’t send it, you have no valid invoice and cannot legally ship products.”
  • NFS-e often requires immediate registration through online systems or APIs, with short deadlines for converting provisional receipts (RPS) to official invoices.

Data Requirements and Format:

  • E-invoices must include comprehensive transaction data in a structured XML format.
  • Key data fields include identifications (CNPJ, address), transaction details (description, quantity, price, CFOP), and tax details (rates, amounts, category codes).
  • Each cleared invoice carries an authorization code from SEFAZ.
  • “The data requirements are extensive and standardized, as Brazil’s aim is to have all information needed for tax enforcement in the electronic document.”
  • “the core data to be provided to authorities are the invoice details in XML format”

E-Reporting and Tax Returns:

  • The cleared e-invoice is the data report for that transaction, eliminating the need for separate continuous transaction reports for invoices.
  • Companies submit aggregate periodic filings (SPED EFD) with tax calculations and invoice summaries.
  • Brazil does not currently issue pre-filled VAT returns for taxpayers based on e-invoice data. “To date there are no pre-filled VAT returns in Brazil”.
  • The 2026 tax reform aims to leverage e-invoice data to automate tax calculation and generate pre-populated tax returns, potentially using a “split payment” mechanism. “Under the forthcoming 2026 tax reform (introduction of CBS/IBS VAT system), the government plans to use e-invoice data to calculate taxes and even generate pre-populated tax returns or summaries”.

Penalties for Non-Compliance:

  • “Brazil imposes strict penalties for failing to comply with e-invoicing obligations.”
  • “Fines can reach 100% of the invoice value for not issuing an invoice or for issuing one that doesn’t meet legal requirements.”
  • Infractions can be treated as tax evasion, leading to criminal charges.
  • Authorities can seize goods transported without an NF-e and shut down businesses for non-compliance. “Businesses have been temporarily shut down for failing to issue invoices as well”.

Archiving and Retention:

  • “Taxpayers must securely archive all electronic fiscal documents for a long retention period.”
  • “Importantly, a recent change extended this retention period: as of May 1, 2025, Brazil standardized the minimum retention for all electronic tax documents to 132 months (11 years) from the date of the document’s authorization.”
  • Companies must maintain the original XML files in a safe, readable format for the entire period.
  • Failing to produce an invoice or losing the file before the retention period expires can result in fines.

Foreign Entities and Digital Services:

  • Historically, foreign companies without a Brazilian establishment could not directly issue Brazilian NF-e/NFS-e.
  • The 2023 tax reform will require foreign suppliers of digital services to Brazil to register in Brazil and issue compliant e-invoices, starting with the new VAT model (CBS/IBS in 2026). “Starting with the new VAT model (CBS/IBS in 2026), foreign suppliers of digital services to Brazil will be required to register in Brazil and issue compliant e‑invoices for those sales.”

Important Dates:

  • November 1, 2025: NFCom (Nota Fiscal de Serviços de Comunicação) becomes mandatory.
  • May 1, 2025: Standardized minimum retention for all electronic tax documents becomes 11 years.
  • January 1, 2026: National NFS-e system becomes mandatory countrywide.
  • 2026: Introduction of new VAT model (CBS/IBS) and planned use of e-invoice data for pre-filled tax returns.

Conclusion:

Brazil’s e-invoicing system is a highly developed and strictly enforced regime designed to maximize tax compliance and minimize fraud. Businesses operating in Brazil must adhere to these regulations and prepare for upcoming changes related to the 2026 tax reform and extended document retention requirements.


INDEPTH ANALYSIS

Brazil’s E‑Invoicing framework is all-encompassing and operates on a continuous transaction control (clearance) model. Electronic invoicing has been mandatory for all businesses and nearly all transactions (goods and services, domestic and cross-border, B2B, B2C, and B2G alike) for over a decade. Invoices must be pre-approved in real time by tax authorities before completion of the transaction, which means data is transmitted at issuance (no post-issuance grace period in general). Key aspects of Brazil’s e‑invoicing and e‑reporting include: [storecove.com], [avalara.com] [avalara.com]

  • Implementation Timeline & Mandate Rollout: Brazil pioneered e-invoicing in Latin America. Legislation emerged in 2005, and electronic invoices became mandatory by 2008 for many taxpayers. The Nota Fiscal Eletrônica (NF-e) for goods was phased in circa 2006–2010, replacing paper invoices nationally. Over time, Brazil expanded the system to cover more transaction types and taxpayers. For example, NFC-e (consumer invoices) were introduced in the 2010s to replace point-of-sale receipts in retail, and by around 2019 virtually all states mandated NFC-e for B2C sales (ensuring even consumer sales are e-invoiced). Service invoices (NFS-e), which were historically managed by each municipality, are now being unified: Over 1,280 municipalities (covering ~70% of service revenue) have joined a new National NFS-e system, which **becomes mandatory countrywide on January 1, 2026. This means that from 2026, the myriad local service invoice models will be replaced by a single national standard for all cities and the Federal District. Other recent milestones include NFCom (Nota Fiscal de Serviços de Comunicação) for telecommunications services, which was created in 2022 and will be mandatory as of November 1, 2025, replacing the old after-the-fact reporting of phone/TV bills with real-time invoicing. Overall, Brazil’s e-invoicing mandates have been introduced with lead time for testing but, once the official go-live date arrives, compliance is expected immediately (there is generally no extended “grace period” after the mandate’s effective date). [storecove.com] [fiscal-req…ements.com], [fiscal-req…ements.com] [edicomgroup.com], [edicomgroup.com] [comarch.com]
    • Grace periods or phased rollouts: Instead of post-mandate leniency, Brazil tends to offer pilot or voluntary adoption phases before the deadline. For instance, companies could test and voluntarily issue NFCom invoices starting March–June 2023, well ahead of the Nov 2025 mandate. Similarly, the national NFS-e was available for early adopters; by Aug 2025, hundreds of municipalities were already issuing in the new system. In a few cases, deadlines were extended for certain taxpayers – for example, small and unincorporated service providers were given an extra few months (from April 3, 2023 to September 1, 2023) to start using electronic invoicing. But beyond such limited deferrals, there is no general grace period once e-invoicing is mandatory – companies must comply from day one or risk penalties. [comarch.com] [ey.com] [storecove.com]
  • Scope of Transactions – Domestic, Import, Export, B2B/B2C/B2G: Virtually all invoiced transactions in Brazil fall under the e‑invoicing mandate. This includes: [storecove.com], [avalara.com]
    • Domestic B2B and B2G: All sales of goods between companies, and supplies to government entities, must be invoiced via NF-e (model 55) and authorized by the state SEFAZ (Secretaria da Fazenda) before goods are delivered. Likewise, services provided B2B or to government require an NFS-e issued through the respective municipal or national system. Government procurements (B2G) have been fully electronic for years, using the same NF-e/NFS-e systems as business transactions. [avalara.com], [avalara.com]
    • Domestic B2C: Consumer sales are also within scope. For goods sold to consumers (retail transactions), businesses issue an NFC-e (Nota Fiscal de Consumidor Eletrônica) – an electronic consumer invoice – typically in real time at the point of sale, replacing old cash register receipts. This ensures even B2C transactions are reported to the tax authorities electronically. For services rendered to individuals (B2C services), an electronic service invoice (NFS-e) must be issued as well (many cities required this; the new national system will cover all such transactions by 2026). In sum, Brazil’s mandate isn’t limited to B2B: any taxable sale to any customer must be electronically invoiced. [storecove.com]
    • Import and Export transactions: Cross-border trades are also captured through e-invoicing requirements. When importing goods, the Brazilian importer is generally required to issue an NF-e to record the entry of goods from abroad into their inventory (this NF-e for import serves to formalize the import in the tax system). For exports, the exporter must similarly issue an NF-e (indicating an export operation) that is cleared by SEFAZ before goods leave the country. In practice, an NF-e is used to accompany any shipment of goods, whether domestic or for export, so exports are very much “in scope” of the e-invoicing system. These measures ensure international movements of goods are reported electronically in real time, just like domestic movements. (Brazil also has a specific electronic invoice model for export shipments, Nota Fiscal de Exportação, which is handled within the NF-e system).
    • Other document types: Brazil’s system extends to specialized electronic fiscal documents for particular scenarios, all of which follow similar principles. Examples include the CT-e (Conhecimento de Transporte Eletrônico) for freight and cargo transportation, the MDF-e (Manifesto Eletrônico) as a manifest of multiple invoices in transit, the NF3e for electricity billing, the BP-e for passenger transport tickets, and now the NFCom for telecom services. Each of these is legislated and must be issued electronically where applicable. In summary, the mandate covers domestic transactions of all types and ensures that even traditionally paper-based or summary-billed sectors (transportation, utilities, telecom) use e‑invoices. Brazil’s clearance model also inherently covers B2G transactions (since government agencies will only accept electronic invoices) and most cross-border scenarios (via import/export NF-e), leaving virtually no gap for a separate “e-reporting” of such transactions – they are already captured by the required e-invoices. [fiscal-req…ements.com], [dpc.com.br]
  • Taxable Persons in Scope (Established vs. Non-Established): All companies established in Brazil (i.e. with a Brazilian CNPJ tax ID) that issue invoices are required to comply with electronic invoicing. This mandate applies across the board – “all businesses in Brazil that issue invoices must use the electronic system”, regardless of size or industry (there are no general exemptions, aside from perhaps some very limited cases like certain microentrepreneurs, most of whom are now included as noted). Even individuals or small proprietors who are required to issue invoices for their activities are increasingly brought into the electronic system (for example, the inclusion of small service providers by 2023). Foreign or non-established entities: Historically, foreign companies without a Brazilian establishment could not directly issue Brazilian NF-e/NFS-e, since using the system requires a local registration and digital certificate. In cross-border scenarios, the obligation fell on the Brazilian party (e.g. the local importer for goods, or the local customer via self-invoice for services) to ensure the transaction is recorded. However, Brazil’s 2023 tax reform will change this for digital services: Starting with the new VAT model (CBS/IBS in 2026), foreign suppliers of digital services to Brazil will be required to register in Brazil and issue compliant e‑invoices for those sales. This means non-established companies will be pulled into the e-invoicing system when they have tax obligations in Brazil. In general, aside from such new cases, the e-invoice mandate is effectively universal for all Brazilian-registered taxpayers – there are no turnover thresholds for exclusion. (Even small businesses under the “Simples Nacional” regime must issue NF-e/NFS-e; many municipalities had allowed manual receipts for tiny operators, but the trend is toward including everyone in the electronic system). [basware.com] [rsm.global], [rsm.global]
  • Data Requirements (Content of the E-Invoice/E-Report): The electronic invoice must include comprehensive transaction data in a structured format defined by the tax authorities. Each NF-e or NFS-e is an XML file containing all the relevant details of the sale. Key data fields include: [avalara.com]
    • Identifications: Unique invoice number and an access key, the issuer’s CNPJ (tax ID) and address, the recipient’s ID (CNPJ or CPF for individuals) and address. [avalara.com], [avalara.com]
    • Transaction details: Date and time of issuance, description of goods or services, quantity, unit price, total amount, and the CFOP (Código Fiscal de Operação) that classifies the type of transaction (e.g. sale, export, transfer). [avalara.com]
    • Tax details: All applicable taxes must be detailed line by line – for goods, this includes ICMS (state VAT on goods), IPI (federal excise), etc., and for services, ISS (service tax). The invoice shows tax base amounts, rates, and amounts due for each tax. Tax rates and amounts, and tax category codes are mandatory fields, ensuring the authorities receive the information needed to calculate liabilities. [avalara.com]
    • Authorization info: Each cleared invoice carries an authorization code or protocol number from SEFAZ as proof of clearance. The XML includes a digital signature (to guarantee authenticity) and a timestamp of approval. For services via the national system, similar authorization and a unique code (and possibly a “Documento de Arrecadação (DNA)” number used for tax payment) are included. [avalara.com]
    • Additional data: The schema provides fields for discounts, freight charges, payment method, and even specific notes (e.g. legal messages, fiscal observations). In some cases additional info is required – for example, for cross-border invoices, information about the export or import declaration; for certain goods (e.g. pharmaceuticals, fuels) there are specific fields for traceability. The data requirements are extensive and standardized, as Brazil’s aim is to have all information needed for tax enforcement in the electronic document.
    • E-Reporting data: Brazil does not have a separate “e-reporting” file for each invoice apart from the invoice itself – the cleared e-invoice is the data report for that transaction. However, companies also submit aggregate periodic filings (such as SPED fiscal ledgers, see below) which summarize or reconcile the invoice data. These filings are electronic and include lists of issued invoices, tax calculation summaries, etc. (The **layout of these returns is also defined by authorities – for instance, the ECD/ECF and EFD files – but they are not invoices per se). In summary, the core data to be provided to authorities are the invoice details in XML format, and because of the clearance model, authorities receive that data essentially instantly for each transaction.
  • Transmission Process and Deadlines: Brazil employs a clearance model with real-time or near-real-time transmission of invoice data to the tax authority. In practice, this means before or at the moment of issuing an invoice, the issuer must send the XML to the government and obtain approval. The NF-e process for goods, for example, is: generate the XML from your ERP, submit it via web service to SEFAZ, and wait for an electronic “authorization” response. Only after approval can the goods be released for shipment (and the seller then provides the buyer with the XML and a paper DANFE as an accompanying document). This is effectively an immediate reporting – the “due date” for transmission is concurrent with issuance; if you don’t send it, you have no valid invoice and cannot legally ship products. Similarly, for NFS-e (services), in many cases the invoice is issued through an online system or via API calls that immediately register it with the municipal or national service tax portal. Some service workflows allow a brief delay by using an RPS (provisional receipt) – but even then the RPS batch must be uploaded and converted to official NFS-e typically within the same day or so (municipal regulations historically often required conversion within next business day, to ensure timely reporting). For the new national NFS-e, a pre-declaration (DPS) is sent for approval and then transformed into the NFS-e, indicating a similar immediate clearance approach. In summary, invoice data must be transmitted immediately at the time of transaction – there is no multi-day lag permitted for standard cases. If the environment is down (either the taxpayer’s system or SEFAZ server), contingency procedures exist (e.g., issuing in “offline mode” and transmitting at the first opportunity). Those contingency rules still impose short deadlines – e.g. if an NF-e is issued in contingency, the XML must be sent to SEFAZ as soon as systems are restored, usually within 24 hours. [avalara.com] [edicomgroup.com], [edicomgroup.com] [edicomgroup.com]
    • E-Reporting timelines: Because every invoice is cleared in real time, Brazil doesn’t require a separate continuous transaction report for invoices (unlike some countries where, for example, B2C invoices are reported in batches later). The clearance itself is the real-time reporting. The notion of “e-reporting” in Brazil mainly comes into play for any transactions or summary information not captured via individual invoices. For instance, companies must still file monthly electronic tax returns (like SPED EFD – Escrituração Fiscal Digital) where they report aggregated tax calculations, and these are due on periodic due dates (typically monthly by the 15th of the following month for ICMS/IPI, for example). However, those returns largely draw on the same invoice data. With the upcoming reform, Brazil aims to leverage the invoice data even more – potentially automating tax calculation and pre-populating tax returns from the e-invoice information. In short, transaction data is transmitted at invoice time, and any additional e-reporting (such as monthly statements) uses that data after the fact, due on specified dates (usually monthly). There is no separate daily/weekly report requirement outside of the invoices themselves. (One exception until 2025 was telecom services, where companies sent monthly data files for all billings – but as noted, NFCom will replace that with real-time invoices from Nov 2025, eliminating the delayed reporting). Thus, by 2026, Brazil’s model is purely clearance-based for both goods and services, meaning data goes to the authorities instantly; any “e-report” is either simultaneous (the invoice) or periodic summaries required for compliance assurance. [vatupdate.com] [comarch.com]
  • Format of E-Invoices and Reports: Brazil’s e-invoices are standardized XML documents. The NF-e, NFS-e, CT-e, NFC-e, etc., each have an XML schema defined by tax authorities (with specific fields for that document type). All invoices must be digitally signed using an ICP-Brasil digital certificate to ensure authenticity. The XML schema versions are updated periodically (for example, NF-e is currently at version 4.0). For e-reporting like SPED filings, the format is typically also electronic (often text or XML files in a prescribed layout) uploaded via the government systems, but the most critical “report” is the invoice itself in XML. Each approved invoice’s XML is stored in the government’s national database as well as by the company. In summary: the required format is XML for invoices, with specific variations: e.g., NF-e model 55 for goods, NFS-e with its own schema for services, and so on. There is also a human-readable representation (DANFE or DANFE-NFS-e) that can be printed but the legal document is the XML. Any data transmissions to authorities are electronic (via web services or portal uploads); paper filing is obsolete in this domain. The standardized format ensures that both state and federal tax authorities receive data in a consistent structure for validation and auditing. [edicomgroup.com], [edicomgroup.com] [comarch.com], [comarch.com] [comarch.com], [edicomgroup.com]
  • Transmission Method: All e-invoice data is transmitted electronically to the tax authority’s systems. For NF-e/NFC-e and CT-e (which are under state/federal jurisdiction), companies use web service endpoints provided by each state’s SEFAZ – essentially, the company’s ERP or middleware sends the XML over the internet to the SEFAZ server and receives a response (authorized or rejected) within seconds. For NFS-e, historically this was done via municipal government web portals or APIs; the new national NFS-e platform provides a centralized web portal, mobile app, and API connectivity to the National Finance Secretariat (SEFIN) servers. In all cases, a secure digital certificate is used to sign and often to authenticate the submission. The timeline for transmission as noted is immediate; in fact, one cannot legally delay sending – the invoice must be cleared first. If an invoice is not cleared (e.g., due to an outage), it’s issued in contingency mode and then transmitted as soon as possible when systems are available (with strict rules, typically within 24 hours). This clearance approach removes the need for any separate deadline like “X days after issuance” – by design, the invoice won’t be valid if it hasn’t been transmitted and authorized almost immediately. Thus, Brazil’s model contrasts with some countries’ e-reporting where data can be sent within a day or two; here the data flow is essentially real-time. [edicomgroup.com], [edicomgroup.com] [avalara.com]
  • Penalties for Non-Compliance: Brazil imposes strict penalties for failing to comply with e-invoicing obligations. Not issuing a required electronic invoice, or issuing it incorrectly (with missing or wrong data, or not obtaining approval), is considered a serious tax offense. Fines can reach 100% of the invoice value for not issuing an invoice or for issuing one that doesn’t meet legal requirements. In other words, the entire transaction value can be penalized, effectively nullifying the sale’s profit. Such infractions may also be treated as tax evasion, leading to further sanctions – including potential criminal charges for tax fraud in egregious cases. In practice, if a company is caught transporting goods without an NF-e, authorities can seize the goods and levy fines. Businesses have been temporarily shut down for failing to issue invoices as well (Brazilian tax authorities regularly conduct inspections; for example, enforcement sweeps have closed establishments on the spot for non-compliance with e-invoicing). Additionally, each state can apply specific fines per document not issued or reported. There are also penalties for related failures, such as: not transmitting contingency invoices in time, failing to maintain archives, or denying access to the XML for customers/tax auditors. Overall, the risk of a 100% invoice-value fine underscores that compliance is mandatory and not optional. Companies also risk having their state tax registration blocked if they systematically fail to issue NF-es, which would prevent them from doing business. The strong enforcement has been a driver for Brazil’s high rate of compliance in electronic invoicing. [storecove.com], [storecove.com]
  • Archiving and Retention Requirements: Taxpayers must securely archive all electronic fiscal documents for a long retention period. By law, electronic invoices and related fiscal documents must be kept for at least 5 years (plus the current year). Importantly, a recent change extended this retention period: as of May 1, 2025, Brazil standardized the minimum retention for all electronic tax documents to 132 months (11 years) from the date of the document’s authorization. This new 11-year requirement (established by SINIEF Adjustment 2/2025) covers NF-e, NFC-e, CT-e, MDF-e, NF3e, BP-e, CT-e OS, GTV-e, DC-e, and NFCom – essentially every type of e-invoice or e-document listed in the legislation. Companies must maintain the original XML files (and any related event records such as cancellations or corrections) in a safe, readable format for the entire period. Each state’s regulations dictate acceptable storage media (commonly on servers or cloud, with backup) as long as the 11-year retention is met. During this time, the data must remain accessible and intact for inspection – tax auditors can at any time ask for the XML of a specific invoice within the past decade. Failing to produce an invoice or losing the file before the retention period expires is itself an offense and can result in fines. (The new rule also specifies that after 11 years, the documents may be purged, aligning all jurisdictions on this timeline.) Businesses need robust digital archiving practices to comply with these rules. In summary, invoices must be archived electronically for 11 years (previously 5), and companies should ensure they can retrieve any invoice and its authorization details on demand. Non-compliance with archival duties can lead to penalties, so this is a critical part of the e-invoicing compliance process. [edicomgroup.com] [dpc.com.br] [dpc.com.br], [dpc.com.br]
  • Use of Data for Tax Returns (Pre-Filled Returns): As of today, Brazilian tax authorities do not issue pre-filled VAT returns for taxpayers based on e-invoice data – taxpayers themselves are responsible for compiling the data from their invoices and filing the appropriate tax declarations (such as monthly ICMS/IPI returns, contributions returns, etc.). However, with the wealth of real-time information collected through e-invoicing, Brazil is moving toward easing compliance burdens by leveraging that data. Under the forthcoming 2026 tax reform (introduction of CBS/IBS VAT system), the government plans to use e-invoice data to calculate taxes and even generate pre-populated tax returns or summaries. In fact, the reform envisions a “split payment” and automated collection mechanism for the new VAT, where tax amounts are determined at invoice issuance and could be remitted directly. This implies that future periodic VAT returns may simply be derived from the invoices already in the system, with the authorities providing a pre-calculation. Some sources indicate the new system will “use e-invoicing data to … generate pre-filled tax returns” as part of the modernized platform. Today, though, Brazil’s existing taxes (ICMS, IPI, ISS, etc.) still require companies to manually consolidate invoice data in monthly SPED reports and tax declarations – these are not pre-filled by the tax authority. Unlike some countries, you won’t receive a provisional VAT return to confirm; you must submit your own and the authorities cross-check it against the e-invoice database. To date there are no pre-filled VAT returns in Brazil, but the direction is clearly toward leveraging real-time invoice data for automated compliance in the near future. Taxpayers should thus expect a shift wherein their role in preparing returns diminishes as the government uses the invoice info (already in its possession) to draft the tax calculations. [vatupdate.com] [rsm.global], [rsm.global]
References and Sources: Brazil’s e-invoicing requirements are grounded in law and detailed by official regulations. Key legal acts include the Ajuste SINIEF 07/2005 (which created the NF-e) and subsequent CONFAZ Ajustes that introduced other document types, as well as the Complementary Law 123/2006 and others that set out taxpayer obligations. The recent Ajuste SINIEF 02/2025 standardized the 11-year retention period. The upcoming changes for 2025–2026 are driven by Constitutional Amendment 132/2023 (tax reform) and a Complementary Law (PLP No. 68/2023) mandating the national NFS-e from 2026. For further details, see official releases by the tax authority (Receita Federal and state SEFAZ portals) and analysis from major advisory firms. Notable resources include: KPMG’s TaxNewsFlash on Brazil’s e-invoicing updates, EY’s global e-invoicing newsletter, and local Brazilian publications (e.g. Domingues e Pinho’s alert on document retention). These, along with the CONFAZ website for legislation and Receita Federal’s own guidance, provide comprehensive external verification of the above information. All evidence indicates that Brazil’s e-invoicing system is a mature, robust regime covering all facets of invoicing and reporting, with new reforms further enhancing its scope and integration into the tax compliance process. [confaz.faz…nda.gov.br], [confaz.faz…nda.gov.br] [edicomgroup.com], [edicomgroup.com] [kpmg.com], [kpmg.com] [ey.com], [ey.com] [dpc.com.br], [dpc.com.br] [storecove.com], [avalara.com]

 


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