Article

Elizabeth Fernandes Pongo Sousa; Raphael José Pereira Freitas

DOI: 10.22167/2675-6528-202602205

Article derived from a Final Course Work (TCC), with content based on the student’s original work and adapted to the editorial format of the Revista E&S with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.

Abstract

This study analyzed the challenges of the Brazilian Tax Reform in the transition and unification stages of consumption taxes, with an emphasis on its operational, managerial, and institutional developments. The objective was to examine, from an applied perspective, how the changes introduced by Constitutional Amendment No. 132/2023 impacted fiscal compliance, the reorganization of internal processes, and the strategic planning of organizations. Methodologically, the analysis was conducted through a structured comparison between the previous tax regime and the new dual VAT model. It sought to identify practical implications associated with the transition, especially regarding governance, risk management, system adaptation, and the articulation between tax, accounting, financial, and technological areas. The results showed that, although the Reform signaled relevant advances in terms of simplification, standardization, and tax predictability, its implementation imposed significant organizational adaptation requirements. These requirements generated impacts on administrative routines, control flows, and companies’ managerial response capacity. As a contribution, the study reinforced the understanding of the Tax Reform as a process of institutional transformation with concrete effects on organizational dynamics, offering an applied reading that brought the normative content closer to its operational and managerial effects in the Brazilian context.

Keywords: Project management; VAT; Administrative modernization; Tax planning; Tax reform.

1. Introduction

The Brazilian tax system is recognized for its high complexity, characterized by the multiplicity of taxes, the overlap of competencies between federative entities, and a high degree of litigiousness. This configuration generates significant compliance costs for companies and citizens, in addition to distortions that affect the country’s economic efficiency and competitiveness (Appy, 2016; Giambiagi, Além, 2011). The fragmentation and difficulty in predicting tax obligations are elements that historically compromise the stability of the business environment (Gobetti, Orair, 2023; OECD, 2022).

The need to reform the national tax system has been a long-standing debate, with decades of attempts that, in large part, resulted in partial or insufficient changes (Lukic, 2023; Schoueri, Barreto, 2023). The current model presents problems such as the cumulativeness of taxes, the regressivity of the tax burden, and legal uncertainty, which contribute to the system’s inefficiency and inequality in the distribution of the tax burden (Rocha, 2022; Moreira, 2013). The lack of standardization and regulatory complexity amplify companies’ operational costs, reinforcing the urgency of structural reform (Pinto, Machado, 2023; IBPT, 2024).

Specialized literature indicates that an efficient tax system should reconcile principles such as equity, simplicity, neutrality, and revenue capacity to minimize distortions and promote economic development (Giambiagi, Além, 2011; OECD, 2022). However, the Brazilian system deviates from these parameters, exhibiting high fragmentation and challenges in administration and oversight (Appy, 2016; Gobetti, Orair, 2023). This scenario drives the search for alignment with international practices, especially the adoption of models based on the Value Added Tax (VAT), common in developed economies (World Bank, 2023; OECD, 2023). The Tax Reform, therefore, transcends mere rate changes, implying a structural reconfiguration with significant economic, institutional, and social impacts (Lukic, 2023).

The relevance of this research is justified by the timeliness of the topic and the intensification of the debate surrounding legislative proposals of great impact, such as Constitutional Amendment Proposals nº 45/2019 and nº 110/2019, which culminated in the approval of Constitutional Amendment nº 132/2023 (Brazil, 2023). The discussions on these proposals go beyond technical aspects, incorporating political, economic, and social dimensions that reflect the complexity of the Brazilian tax system (CNI, 2023; FIESP, 2023). The diversity of interests and the breadth of the proposed changes highlight the need for critical and well-founded analyses, capable of contributing to the understanding of the impacts of the Reform (CNC, 2023; IBPT, 2024).

Given this scenario, it becomes essential to systematically analyze the main challenges and implications associated with Tax Reform in Brazil, focusing on its operational and organizational developments. This study, therefore, is justified by offering an applied perspective, aimed at interpreting the practical repercussions of the reform on business management and the adaptation of organizations to the new tax model. The objective of this work is to examine, from an applied perspective, how the changes introduced by Constitutional Amendment No. 132/2023 have impacted tax compliance, the reorganization of internal processes, and the strategic planning of organizations.

2. Material and Methods

The methodology of this work is characterized as a research of an applied nature, with a descriptive-analytical approach, focused on the analysis of the operational impacts of Tax Reform on project management in organizational contexts. The study addressed the transition to the dual VAT model (IBS and CBS), established by Constitutional Amendment No. 132/2023, and structured an analytical model to interpret its practical effects on project processes, risks, and governance. To this end, a comparative analysis “framework” was built between the previous tax regime and the new model, aiming to translate regulatory provisions into managerial impact variables and evaluate how the legal changes translate into operational and organizational requirements.

For the operationalization of the model, secondary data of a normative and institutional nature were used, including legislative documents, technical notes, and specialized studies. These sources, such as documents related to Constitutional Amendment No. 132/2023, technical notes from the Ministry of Finance, reports from the Tax Citizenship Center, opinions from the National Congress, studies from economic institutes, scientific publications, and comparative analyses of tax systems, served as input for the analytical modeling and the identification of the Reform’s guidelines. For more details, see Brazil (2023a, 2023b, 2023c, 2024), CCiF (2023), CNC (2023), CNI (2023), FIESP (2023), IBPT (2024), and OECD (2022, 2023).

The methodological procedure was structured in sequential steps: (a) identification and systematization of normative guidelines; (b) translation of these guidelines into analytical categories for project management; (c) construction of comparative matrices between the previous tax model and the new system; and (d) application of these matrices in the analysis of typical organizational scenarios, evaluating impacts on scope, processes, risks, and governance. This approach allowed for the simulation of operational effects of the tax transition, characterizing the study as an analytical application oriented towards organizational reality.

Additionally, risk management, strategic planning, and process analysis instruments were incorporated to support the interpretation of the identified impacts, allowing for the identification of critical points and adaptation demands. The data were organized into structured metadata, enabling its systematic analysis and the replication of the proposed model. The study’s emphasis focused on the operationalization of the normative description in a management context, generating inferences for decision-making and organizational strategic planning.

The research was developed in the city of São Paulo, using entirely public data that does not involve human beings or confidential information, eliminating the need for identification of specific institutions. The methodological conduction sought to ensure analytical rigor and practical applicability, proposing a replicable model for evaluating the impacts of the Tax Reform on project management.

3. Results and Discussion

The analysis of the results demonstrated that the Tax Reform represents a structural inflection point in the Brazilian fiscal model, especially in the reorganization of consumption taxes. The substitution of multiple levies by a dual Value Added Tax system (IBS and CBS) shows potential for regulatory and operational simplification, reducing the historical fragmentation of the national tax system (Appy, 2016, Gobetti, Orair, 2023). The standardization of calculation and credit rules contributes to greater transparency and predictability, essential aspects for economic efficiency and legal certainty (OECD, 2022, World Bank, 2023). This convergence between empirical findings and theoretical foundations of taxation reinforces the idea that less cumulative systems generate less distortion on productive decisions and greater economic neutrality (Giambiagi, Além, 2011, Rocha, 2022).

The transition phase, however, proved particularly complex, configuring a period of administrative overload and institutional reorganization. The simultaneous coexistence between the previous regime and the new tax model requires companies to deeply review their fiscal, financial, and accounting routines (Brazil, 2023, CCiF, 2023). This scenario produces a temporary increase in complexity, contradicting, in the short term, the central objective of simplification. Such a phenomenon confirms the theoretical perspective that large-scale structural reforms imply initial adaptation costs, demanding investments in technology, professional training, and review of internal processes to ensure compliance and mitigate risks (CNI, 2023, FIESP, 2023).

The internal reorganization of companies highlights the importance of corporate governance and project management as strategic instruments for adapting to regulatory changes. Organizations with consolidated planning and control methodologies demonstrated a greater capacity to respond to new fiscal requirements (Matos, Melo, 2025, Lukic, 2023). The integration between tax, accounting, financial, and technological areas proved to be decisive in reducing inconsistencies and avoiding rework. This finding reinforces the hypothesis that the Tax Reform goes beyond the legal field, assuming a managerial and organizational dimension that directly impacts the operational efficiency of institutions (Appy, 2016, Pinto, Machado, 2023).

From an economic perspective, the results indicate a potential reduction in operational costs in long production chains, especially in the industrial and export sectors. The elimination of cumulativeness and the standardization of tax credits tend to improve companies’ cash flow and reduce distortions associated with the accumulation of tax credits that are difficult to offset (IBPT, 2024, OECD, 2023). This dynamic brings the country closer to models adopted by developed economies, in which consumption taxation does not penalize exports and preserves fiscal neutrality (World Bank, 2023). However, regulatory consolidation is still necessary to ensure that such benefits materialize in a stable and lasting manner (Brazil, 2024).

In contrast, service-intensive sectors showed a higher level of uncertainty regarding the final impacts of effective tax rates and the federal redistribution of revenues. The eventual increase in the tax burden for certain segments may generate structural adjustments in the market, influencing prices, margins, and business strategies (CNC, 2023, Holanda González, 2024). This reality highlights that, although the reform seeks global neutrality, its distributive effects may vary according to the economic profile of activities, requiring continuous monitoring and eventual recalibration of public policies (Moreira, 2013, Kuntz, 2021).

From a federal perspective, the transition to the destination-based taxation criterion represents a significant advance in reducing the tax war and promoting greater competitive equity among states. The centralization of incidence rules tends to reduce interpretative disputes and litigation, strengthening regulatory predictability (Gobetti, Orair, 2023, Schoueri, Barreto, 2023). However, the distribution of revenues and financial compensation mechanisms remain sensitive points, whose effectiveness will depend on the coordination capacity among federative entities and political stability in the implementation process (Brasil, 2024, Lukic, 2023).

The analysis also showed that the Reform has relevant implications for fiscal justice. Although simplification and neutrality are important advances, the challenge remains to mitigate the regressivity inherent in consumption taxation (Kuntz, 2021, Holanda González, 2024). Instruments such as the partial refund of taxes to lower-income groups and the selectivity of rates will be fundamental to ensuring greater distributive balance (OECD, 2022). Thus, the social dimension of the Reform will depend on adequate regulation and the effective implementation of compensatory mechanisms (World Bank, 2023).

Another relevant aspect identified refers to the technological modernization driven by the reform. The need to update ERP systems, reparameterize accounting software, and adopt new digital routines contributes to accelerating digital transformation processes in organizations (FIESP, 2023, IBPT, 2024). Although such a movement generates high initial costs, it also creates an opportunity to improve internal controls, automate routines, and integrate data more efficiently. In this sense, the reform acts as a catalyst for administrative innovation and strengthening of corporate governance (CNI, 2023, Lukic, 2023).

Additionally, the results suggest that greater tax transparency could positively influence the perception of national and foreign investors. Regulatory predictability and standardization of rules reduce regulatory risks and increase confidence in the institutional environment (OECD, 2023, World Bank, 2023). In the long term, this stability tends to favor productive investments, stimulate competitiveness, and contribute to sustainable economic growth (Giambiagi, Além, 2011). However, the consolidation of this perception will depend on the coherence in the application of norms and political stability during the transition period (Brazil, 2024).

It should also be noted that the analysis has limitations inherent to the initial stage of the Reform’s implementation. The absence of complete regulation and the lack of consolidated data on revenue collection and sectoral impact restrict a full quantitative evaluation of the results (Brazil, 2024, IBPT, 2024). Despite this, the comparative approach adopted allowed for the identification of trends, challenges, and opportunities, offering a consistent overview of the structural effects of the tax change (Matos, Melo, 2025).

In summary, the results discussed indicate that the Tax Reform lays promising foundations for a more rational, transparent fiscal system aligned with best international practices (OECD, 2022, World Bank, 2023). However, its definitive effects will depend on the quality of the complementary regulation, the adaptability of organizations, and the federal coordination in implementing the new rules (Lukic, 2023; Schoueri, Barreto, 2023). The Reform is therefore configured not only as a normative change but as a systemic process of institutional transformation that requires strategic planning, robust governance, and continuous monitoring so that its objectives of simplification, efficiency, and fiscal justice are fully achieved (Appy, 2016, Pinto, Machado, 2023).

4. Conclusion

This study examined the repercussions of the changes introduced by Constitutional Amendment No. 132/2023 on tax compliance, internal process reorganization, and strategic planning of organizations, from an applied perspective. It was found that the Tax Reform, by instituting the dual Value Added Tax model (IBS and CBS), signaled a significant advance in terms of regulatory and operational simplification, standardization of rules, and greater tax predictability. However, the transition phase proved to be a period of heightened complexity, requiring companies to conduct a thorough review of their tax, financial, and accounting routines, in addition to investments in technology and training. It was observed that organizational adaptability was directly linked to the maturity of corporate governance and the effectiveness of project management, with the integration between the tax, accounting, financial, and technological areas being decisive in mitigating risks and ensuring compliance.

The main contribution of this work lies in strengthening the understanding of Tax Reform as a process of institutional transformation with concrete effects on organizational dynamics, bringing normative content closer to its operational and managerial developments in the Brazilian context. Although the reform has the potential to reduce operational costs in long supply chains and promote greater competitive equity between states through destination-based taxation, uncertainty was identified for service-intensive sectors and challenges in mitigating the regressivity inherent in consumption taxation. The analysis has limitations inherent to the initial stage of the Reform’s implementation, given the absence of complete regulation and consolidated data on collection and sectoral impact. It is suggested that future studies monitor the normative consolidation and the effectiveness of compensatory mechanisms, as well as evaluate the sectoral impacts and investor perception throughout the transition period, for a more in-depth understanding of its definitive effects.

Bibliographic References

Appy, B. 2016. Porque o sistema tributário brasileiro precisa ser reformado. 2. ed. São Paulo: Centro de Cidadania Fiscal.

Brasil, 20 [Referência completa não encontrada no documento original]

Brasil. 2023a. Emenda constitucional nº 132, de 20 de dezembro de 2023. Diário Oficial da União, Brasília, DF.

CNC – Confederação Nacional do Comércio. 2023. Reforma tributária: impactos sobre o setor de comércio e serviços.

CNI – Confederação Nacional da Indústria. 2023. Impactos econômicos da reforma tributária.

FIESP – Federação das Indústrias do Estado de São Paulo. 2023. Relatório técnico sobre a reforma tributária e os setores industriais.

Giambiagi, F., Além, A. C. 2011. Finanças públicas: teoria e prática no Brasil. 4. ed. Rio de Janeiro: Campus.

Gobetti, S. W., Orair, R. O. 2023. Reforma tributária e federalismo fiscal: uma análise das propostas de criação de um novo imposto sobre o valor adicionado para o Brasil. Brasília: IPEA.

IBPT – Instituto Brasileiro de Planejamento e Tributação. 2024. Estudo técnico: efeitos do IVA dual na economia brasileira. Curitiba.

Lukic, M. S. R. 2023. Reforma tributária no Brasil: ideias, interesses e instituições. Rio de Janeiro: FGV.

Moreira, C. G. 2013. Faces complementares do estado fiscal: da equidade à eficiência da tributação. Economic Analysis of Law Review, v. 4, n. 2.

OCDE – Organização para a Cooperação e Desenvolvimento Econômico. 2022. Consumption tax trends. OECD Publishing.

OCDE – Organização para a Cooperação e Desenvolvimento Econômico. 2023. Tax policy reforms 2023. OECD Publishing.

Pinto, E., Machado, J. 2023. Tributação sobre consumo no Brasil e no mundo: diagnósticos e caminhos de reforma. Revista de Economia Contemporânea, v. 27, n. 1.

Rocha, S. A. 2022. IVA no Brasil: conceitos, desafios e perspectivas. Rio de Janeiro: Forense.

Schoueri, L. E., Barreto, P. A. 2023. Direito tributário: reforma e perspectivas. São Paulo: Thomson Reuters.

World Bank. 2023. Overview of Brazil’s tax reform. Washington, DC.

Article originating from the Course Conclusion Work of the Specialization in Tax Management of the MBA USP/Esalq

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