Place of Supply under Brazil’s IBS/CBS Reform

Brazil’s consumption tax reform introduced a dual VAT model based on the tax on goods and services (imposto sobre bens e serviços, IBS) and the contribution on goods and services (contribuição sobre bens e serviços, CBS). Within that framework, place-of-supply rules play a significant role in giving effect to the destination principle, determining the juridical destination of consumption and supporting revenue allocation among federative entities. Complementary Law No. 214/2025 addresses the subject mainly through articles 10 and 11, which define when and where the taxable event is deemed to occur. This article examines that framework in four parts: supplies of goods, services and intangibles; supplies without physical presence; imports and exports; and other specific rules relevant to place-of-supply analysis.