Brazil’s tax reform for compounding pharmacies: what changes on the invoice from 2026 to 2033

October 20, 20266 min readBy VUpharma

Brazil’s consumption tax reform started to appear on invoices in 2026 and only ends in 2033. For a compounding pharmacy, the starting point is still the same: how each sale is taxed today.

This guide summarizes what the law and the acts published up to October 2026 say, and what is worth preparing now. The tax classification of each product remains a decision for the pharmacy to make with its accountant.

First, which invoice each sale requires

In 2020, the STF (Brazil’s Supreme Federal Court) ruled (Tema 379) that a made-to-order compounded formula pays ISS (the municipal service tax), as a service under subitem 4.07 of the list in LC 116/2003. An off-the-shelf medicine that the pharmacy produces and offers to the public, on the other hand, pays ICMS (the state tax on goods).

In practice, the made-to-order formula goes out with an NFS-e (service invoice) and the municipality’s ISS. The ready-made product goes out with an NF-e or NFC-e (goods invoices) and ICMS. In an order with both, each part goes out with its own invoice. Services in the pharmacist consultation room also pay ISS and go out with an NFS-e.

Since January 2026, municipalities must accept the national-standard NFS-e, issued through the Emissor Nacional (the national issuing system) or through their own system linked to the national environment (LC 214/2025, art. 62).

2026: the test year

In 2026, invoices start to show CBS (the new federal tax on goods and services) at 0.9% and IBS (the new state and municipal tax) at 0.1% alongside today’s taxes. The calculation is for information only: businesses that meet their reporting obligations pay nothing extra (LC 214/2025, arts. 343, 346 and 348).

Ato Conjunto RFB/CGIBS nº 4/2026, a joint act of the Federal Revenue Service and the IBS Management Committee, set the mandatory dates for businesses outside Simples Nacional (Brazil’s simplified tax regime for small businesses):

NF-e and NFC-e: since August 3, 2026.
NFS-e: since October 1, 2026, as a general rule. Some services, such as digital platforms and rentals, from December 1, 2026.

Each item on the invoice gets an IBS and CBS group, with the CST, the tax classification (cClassTrib), and the bases and rates for CBS and for state and municipal IBS.

There was some leniency at the start, with fines suspended until the end of July 2026 and the automatic rejection of invoices without the IBS and CBS group postponed. The obligation to fill in the fields, however, still stands.

Simples Nacional: from 2027

For a pharmacy under Simples Nacional, the IBS and CBS fields become mandatory on all tax documents on January 1, 2027 (Ato Conjunto nº 4/2026). Before that, from November 1, 2026, Simples businesses issue their NFS-e through the Emissor Nacional (Resolução CGSN nº 191/2026).

Under Simples, IBS and CBS are paid within the DAS, the single monthly Simples payment. LC 214/2025 (art. 41, § 3) also allows a Simples business to calculate and pay both taxes under the regular regime, outside the DAS, under the terms of LC 123/2006. It is a calculation to make with your accountant. The option is made per semester: for the first half of 2027, the deadline is October 30, 2026, on the Simples Nacional Portal (Resolução CGSN nº 186/2026, as amended by nº 194/2026).

The 60% reduction for compounded medicines

Art. 133 of LC 214/2025 reduces IBS and CBS rates by 60% on the supply of medicines registered with Anvisa or produced by compounding pharmacies. Excluded are the zero-rated medicines in art. 146: medicines registered with Anvisa for areas such as oncology and rare diseases, a list that does not include compounded medicines.

For manufactured or imported medicines, the law makes the reduction conditional on passing it on to the price, either through a commitment with the Federal Government and the IBS Management Committee or through the CMED (drug pricing board) mechanism (art. 133, § 2). Whether this condition applies to your pharmacy is a question for your accountant.

Two points to watch. The reduction applies to medicines: a compounded cosmetic or supplement may be classified differently. And under Simples Nacional, if IBS and CBS stay within the DAS, the reduction does not reach the pharmacy directly.

From 2027 to 2033: the transition

2027: CBS starts being charged and replaces PIS and Cofins, which cease to exist. IBS stays at 0.1% (0.05% state and 0.05% municipal) in 2027 and 2028.
2029 to 2032: ICMS and ISS fall to 9/10, 8/10, 7/10 and 6/10 of the original rates, and tax incentives shrink in the same proportion. IBS rises to compensate.
2033: ICMS and ISS cease to exist, and consumption is taxed by CBS and IBS.

The Imposto Seletivo (selective tax), which also starts in 2027, applies to goods and services harmful to health or the environment, not to medicines. Until 2032, each invoice calculates both today’s taxes and the new ones, and the split between ISS and ICMS still applies.

What about SPED (digital tax bookkeeping)?

EFD ICMS/IPI: each state defines who must file it. Simples Nacional businesses are usually exempt, as in São Paulo, but some states require it, such as Pernambuco.
EFD-Contribuições: for businesses outside Simples Nacional. With the end of PIS and Cofins in 2027, this obligation will change, according to Receita Federal (Federal Revenue Service) acts.
Bloco H: this is the inventory record within the EFD ICMS/IPI, usually as of December 31. It is drawn from inventory, which needs to have been checked.

What to prepare now, with your accountant

Separate made-to-order formulas from ready-made products. The product records need to show what is a made-to-order formula (NFS-e, ISS) and what is an off-the-shelf product (NF-e or NFC-e, ICMS).
Classify each product. NCM, CST and the IBS and CBS cClassTrib go in the product record, with the 60% reduction wherever your accountant considers it applies.
Plan for exceptions. The classification in the product record is the default, but it may change depending on the transaction and the recipient, as in some sales to public bodies.
Confirm the tax regime. Simples Nacional, Lucro Presumido or Lucro Real (presumed or actual profit). Under Simples, decide whether IBS and CBS stay in the DAS or move to the regular regime (for the first half of 2027, by October 30, 2026).
Check the NFS-e. Outside Simples, find out whether it is issued through the Emissor Nacional or through the city’s own system. Under Simples, it is issued through the Emissor Nacional from November 1, 2026.
Review the first invoices. While the calculation is for information only, compare the IBS and CBS fields with what your accountant expects.

Where VUpharma comes in

At VUpharma, Vitória Lemos, the AI agent for the tax module, prepares the invoice for each order with the classification your accountant set for each product, with the IBS and CBS fields already in place. She flags any product without a classification before billing and, at month-end, prepares the SPED files from the invoices and inventory.

People make the decisions. The invoice is only issued when someone on the team confirms billing, and the accountant checks the tax calculation and submits the SPED. Meet the agents, see the workflow in a demo or find out how we migrate all your pharmacy’s data, at no cost, so you can review it before going live.

Sources

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