Brazil could extend e-invoicing scope to include foreign businesses

Brazil’s major tax reform is creating new e-invoicingElectronic invoicing - widely referred to as e-invoicing - is the exchange of a digital document between a supplier and a buyer. E-invoices are issued, transmitted and received in a structured data format that enabled automatic and electronic processing. They contain data in a machine-readable format so that an AP system can read an invoice without manual data entry, leading to faster and more efficient invoicing. requirements for businesses outside the country, meaning foreign companies selling into Brazil will need to start looking at how they issue and report invoices.

The changes form part of Brazil’s move towards its new IBS and CBS consumption taxes, which will gradually replace several existing taxes. As part of this wider reform, Brazil is also updating its electronic fiscal document system so that invoices can capture and report the new tax information.

For non-resident businesses, the change is particularly important. Regulations published earlier this year introduced an obligation for foreign entities carrying out transactions subject to IBS and CBS to issue electronic invoices in line with requirements set by the Brazilian tax authorities. A new implementation calendar has now set 1st December 2026 as an important date for the rollout of several electronic documents.

This is expected to affect foreign businesses supplying areas such as digital services, software and other taxable supplies into Brazil. However, some of the practical details are still being worked out. It is not yet fully clear which transactions will create an obligation for non-resident businesses, how those businesses will register, or whether they will use the standard Brazilian NF-e process or a separate model.

For foreign businesses, though, this is not something to leave until the final rules are published. E-invoicing changes can have a knock-on effect across ERPEnterprise resource planning (ERP) is a type of software that organisations use to manage main business processes. and billing systems, tax determination, master data and integrations. Businesses will need to make sure they can calculate the right tax, capture the required information and produce invoices in the format expected by the Brazilian authorities.

The wider reform is already creating a more complex transition, with existing taxes and the new IBS and CBS operating alongside each other as Brazil moves towards the new system. That makes it even more important for businesses to understand how their current systems will handle Brazilian transactions during the change.