Under Brazil’s new IBS/CBS/IS system, receiving an advance payment itself triggers tax, shifting the taxable event from delivery to payment and requiring businesses to issue a debit NF-e type 06, report tax in the payment period, and later deduct it upon final delivery.
To prevent double taxation, the final invoice must reference advance payments via , automatically offsetting tax already paid and requiring ERP systems to fully track, link, and reverse advance-payment taxation where necessary.
Brazil: Advance Payments Are Now Taxable
Public
Brazil
Author: Ivana Picajkić
Category:
Fiscal subject related
Views:
1205
Content accuracy validation date:
09.02.2026
Content accuracy validation time:
09:28h
Before the Tax Reform, tax was generally due only when goods or services were delivered.
Now, under the new system, receiving an advance payment itself triggers tax for IBS, CBS and IS. In other words, tax is no longer linked only to delivery, it can arise earlier, when money is received.
Whenever a business receives an advance payment, it must:
- Issue a Debit Invoice (NF-e type 06 – Advance Payment),
- Calculate and report the tax on the amount received in the period of payment,
- Later deduct that tax when the goods or services are actually delivered, so the tax is not charged twice.
Systems must be able to:
- Issue and store NF-e type 06 for each advance payment,
- Record the tax (IBS, CBS, IS) in the payment period,
- Link advance payment invoices to the final invoice using the <gPagAntecipado> reference,
- Automatically deduct tax already paid when the final supply occurs.
Simple example
A supplier receives advance payments before delivering goods.
January 2026 – Advance payment of R$ 100
- Item value: R$ 80
- Tax rate: 25%
- IBS: R$ 20 (declared in January)
- Debit NF-e type 06 is issued
February 2026 – Advance payment of R$ 150
- Item value: R$ 120
- Tax rate: 25%
- IBS: R$ 30 (declared in February)
- Another debit NF-e type 06 is issued
March 2026 – Goods are delivered
- Total transaction value: R$ 450
- Total IBS due: R$ 90
- The final NF-e references the January and February debit invoices via <gPagAntecipado>
Result:
R$ 50 of IBS was already paid in advance (R$ 20 + R$ 30), so only R$ 40 is paid in March.
The <gPagAntecipado> group is mandatory when delivery is linked to advance payments.
Its role is simple:
- It links the advance payment invoices to the final invoice,
- It ensures tax already paid is automatically deducted,
- It prevents double taxation.
If the contract is cancelled and no supply takes place:
- Use the “Non-occurrence of supply with advance payment” event,
- This event adjusts the tax linked to the advance payment,
- It should only be used when no further deliveries will occur.
Advance taxation applies when:
- A customer pays a down payment,
- Payments are made in instalments before delivery,
- The full amount is paid before delivery,
- A service is paid in advance.
In all cases, a debit NF-e type 06 must be issued for the amount received.
Under the new tax system:
- Money received = taxable event,
- Advance payments must be invoiced and taxed immediately,
- The final invoice must deduct what was already paid,
- ERP systems must fully support advance-payment tracking and references.
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