What does the Brazilian tax reform change in drawback?
One thing changes and another disappears. Payment of IBS and CBS, the two consumption taxes created by the reform, is suspended on imports while the goods sit under a special processing regime, and that suspension reaches both imported and locally bought inputs. Source: Complementary Law 214/2025, articles 90 and 90, paragraph 2.
What disappears is half the menu. Article 91 of the same law states plainly that the exemption and refund modalities of drawback do not apply to IBS and CBS. Companies using drawback exemption to rebuild stock will keep the import duty exemption, and will have to handle the two new taxes another way.
Requirements and conditions for the suspension were handed to secondary regulation (article 90, paragraph 3). The framework already exists in Decree 12,955 of 29 April 2026, which regulates CBS, and in CGIBS Resolution 6 of 30 April 2026, which regulates IBS. The operational detail inside the drawback module still depends on a specific joint act from both tax authorities, so this is a live file, not a settled one. Read it alongside the guide to tax reform on imports into Brazil.