The biggest reform of the Brazilian tax system in decades is already underway. For the tourism sector — hotels, inns, travel agencies, tour operators, restaurants and destinations — the period 2026–2033 demands immediate attention. Not because the tax will become more expensive, but because the rules of the game change completely.
1. What is the Tax Reform in Tourism?
The reform, structured by Constitutional Amendment 132/2023 and regulated by Complementary Law 214/2025, replaces five taxes — PIS, COFINS, IPI, ICMS, and ISS — with a Dual VAT model, composed of two new taxes:
- CBS (Contribution on Goods and Services) — federal, replaces PIS, COFINS and IPI;
- IBS (Tax on Goods and Services) — state and municipal tax, replaces ICMS and ISS.
The central logic is broad non-cumulativeness: the tax is levied on the value added at each stage of the chain, and the credit can be used by the buyer. This represents a structural change in how tourism companies price, invoice, and manage their taxes.
There is also the Selective Tax (IS), aimed at goods considered harmful to health or the environment (cigarettes, alcoholic beverages). For most tourism businesses, its impact will be temporary.
2. Timeline: when each change happens
The transition is gradual and anticipates almost a decade of coexistence between the current system and the new one.
2026 — NOW Testing phase: CBS 0.9% + IBS 0.1% with no real financial effect. Adaptation of NFS-e systems. Critical decision for the Simples Nacional (Brazilian simplified tax regime) until September 2026.
2027 CBS (Contribution on Goods and Services) begins to be effectively charged. Split Payment enters an optional phase between companies. End of PIS/COFINS credits under the old regime.
2029–2032 Gradual reduction of ICMS and ISS with an equivalent increase in IBS. Period of greater operational complexity — two systems coexisting.
2033 Full implementation of the new system. Complete elimination of old taxes. Dual VAT fully operational.
⚠ ATTENTION — IMMEDIATE DEADLINE
Companies opting for the Simples Nacional tax regime must decide by September 2026 whether to remain in the simplified regime or migrate to the regular IBS and CBS regime starting in January 2027. This choice is IRREVERSIBLE after November 2026 and requires a case-by-case analysis.
3. Tax rates for tourism: what the law says
The tourism sector has secured a differentiated tax regime. The legislation provides for a 40% reduction in the standard IBS and CBS rates for the following segments:
| Segment | Estimated Standard Rate | With a reduction of 40% | Status |
| Accommodation (hotels, guesthouses) | ~26,5% | ~15,9% | ✔ Confirmed |
| Travel and tourism agencies | ~26,5% | ~15,9% | ✔ Confirmed |
| Theme and amusement parks | ~26,5% | ~15,9% | ✔ Confirmed |
| Food (meals, non-alcoholic) | ~26,5% | ~15,9% | ✔ Confirmed |
| Regional aviation | ~26,5% | ~15,9% | ✔ Confirmed |
| Alcoholic beverages | ~26,5% | Full tax rate | ✘ No reduction |
| Third-party resellers | ~26,5% | Full tax rate | ✘ No reduction |
* Final rates will still be set by CGIBS and the Federal Revenue Service. Percentages are estimates based on current legal parameters.
📌 IMPORTANT NOTE
The reduction in 40% does not automatically guarantee a lower tax burden for everyone. The final result depends on each company's cost structure, the loss of previous benefits (such as PERSE, which ended in April 2025), and the ability to take advantage of new tax credits.
4. Practical impacts by segment
Hospitality & Accommodation
The tax rate has been reduced to approximately 15.91% of the total tax (TP3T), but corporate clients will not be able to claim tax credits for IBS/CBS paid on hosting—which puts pressure on margins in B2B contracts and may generate demand for discounts. Contract review is urgent.
Travel Agencies & Tour Operators
The tax base changes radically. The tax is levied on the total value of the service provided, not just the commission. Detailed control of revenues, fees, and transfers will be required in the electronic invoice (NFS-e).
Gastronomy & Food & Drinks
Prepared meals and non-alcoholic beverages have a 40% reduction. Alcoholic beverages and resales face the full tax rate. Accurate segregation of revenue at the point of sale is mandatory to avoid penalties.
Destinations & Public Power
The IBS (Brazilian Tax System) transfers part of the revenue to the municipality where the service is consumed—not where the company is headquartered. This can benefit inbound tourist destinations and changes the logic of local revenue collection.
5. Split Payment: the biggest impact on cash flow.
Split Payment is the mechanism that automatically separates the tax amount at the time of payment. When a company receives payment via Pix, credit card, or bank slip, the financial system will retain the IBS and CBS portion and transfer it directly to the tax authorities. The company will only receive the net amount.
Currently, companies receive the full amount upfront and have days or weeks to collect it. This interval is often used as informal working capital. With Split Payment, this "float" disappears.
HOW IT WORKS IN PRACTICE
Example: A hotel invoices R$ 10,000 in lodging. With Split Payment, R$ 1,590 (estimated effective tax rate of ~15.9%) is automatically withheld at the time of payment by card. The hotel receives R$ 8,410 directly, without needing to hold the amount for later collection.
- 2026 No effective Split Payment. Testing phase with a symbolic rate.
- 2027 Split Payment is optional in B2B transactions.
- 2028 onwards Progression towards mandatory status. Extension to IBS.
For the tourism, Liquidity pressure will be greater for companies with low credit utilization, intense seasonal operations, and high dependence on working capital. Financial planning needs to be reviewed before 2027.
6. What to do now: checklist for 2026
The actions below should be initiated immediately — many are due in September or November 2026:
- Comprehensive tax diagnosis: assess your current tax burden, taxes collected, credits used, and current benefits. Only with this overview is it possible to compare it with the new scenario.
- Decision regarding the Simples Nacional tax regime by September 2026: discuss with your accountant whether it is worthwhile to maintain the simplified regime or migrate to the regular IBS/CBS system starting in 2027.
- Update to tax invoicing systems: the NFS-e (Brazilian electronic invoice) now requires new fields (Tax Situation, Tax Classification, Operation Indicator Code).
- Review of long-term contracts: include economic and financial rebalancing clauses to absorb variations in the tax burden during the transition.
- Revenue segregation: especially for gastronomy (alcoholic vs. non-alcoholic beverages) and agencies (commission vs. package vs. fees).
- Projecting the impact of Split Payment on cash flow: simulate liquidity scenarios for 2027 and 2028.
- Renegotiating with suppliers: be prepared to adjust payment terms due to lower cash availability after the implementation of Split Payment.
- Assessment of available tax credits: the new system expands the right to credit on various purchases — mapping which inputs generate credit can reduce the effective tax burden.
7. A word about tourist destinations
For municipalities and tourism governance bodies, the reform brings a significant change: the IBS (Tax on Goods and Services) is collected at the point of consumption—not at the headquarters of the service provider. This means that municipalities with a high influx of incoming tourists can benefit from a larger tax base, even if the companies are headquartered in other cities.
Furthermore, greater tax transparency and traceability of operations should make it easier to measure the economic impact of local tourism—a figure still underestimated by most Brazilian municipalities.
Now is the ideal time for tourist destinations to invest in data intelligence and governance systems that allow them to monitor the sector's economic activity with increasing precision.
8. Conclusion: the preparation window is open.
Tax reform is not an immediate threat to the tourism sector — but it is a structural shock that requires preparation. Companies that wait to understand the new rules in 2027 or 2028 will face a double challenge: adapting systems and contracts amidst the full operation of the new regime.
Those who prepare now — with tax diagnostics, system updates, contract review, and cash flow planning — will be in a strategically advantageous position. In a sector with sensitive margins like tourism, those who understand the rules before their competitors preserve profitability.
2026 is the year to get our house in order. The transition has already begun.
Sources consulted:
Conjur (Aug/2026) · Panrotas (Jul/2026) · Jornal Tribuna (Jul/2026) · Monde/Ajuda (2026) · Simpleshotel Blog · Thomson Reuters Brasil · e-Auditoria · Lei Complementar 214/2025
