Tax Reform and Its Impacts on the Electro-electronic Sector: Comparison between the Current Model and the Dual VAT

Jéssica Nayara de Souza; Raissa Alvares De Matos Miranda

DOI: 10.22167/2675-6528-202603026

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 E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.

Abstract

The Brazilian Tax Reform, established by Constitutional Amendment No. 132/2023, aimed to modernize the tax system by reducing its complexity, cumulativeness, and legal uncertainty. The impact of the reform on the tax management of companies in the electro-electronic sector was analyzed, focusing on the tax burden, pricing, operating margin, and cash flow. The research combined documentary analysis, literature review, and empirical simulations, using real data from the financial statements of a representative company in the sector. The results indicated that the reform contributed to process simplification, increased transparency, and tax neutrality, promoting greater fiscal efficiency and predictability. A significant reduction in the residual tax cost was observed, which decreased from approximately R$ 1.502 billion under the current system to R$ 249.2 million in the baseline scenario of 28% for IBS and CBS, representing a decrease of 83.4%. The simulation of a representative product also showed a reduction in the final price from R$ 1,390.00 to R$ 1,280.00. It was concluded that the reform represents an advancement in the rationalization of the Brazilian tax system and in strengthening tax management in sectors with high consumption tax intensity, such as electro-electronics, although its implementation requires technological adaptation and process restructuring.

Keywords: Revenue efficiency; Price formation; Fiscal management; Tax neutrality; Consumption taxation.

1. Introduction

The Brazilian tax system is recognized for its high complexity, characterized by an extensive dispersion of norms and the partial cumulativeness of taxes. This structure results in the incidence of taxation at various stages of the production chain, generating the so-called cascade effect that compromises economic efficiency and reduces companies’ competitiveness. Within the scope of consumption taxation, these limitations are intensified by the coexistence of multiple taxes, such as the Tax on Circulation of Goods and Services (ICMS), the Service Tax (ISS), the Social Integration Program (PIS), and the Contribution for the Financing of Social Security (COFINS). These taxes are administered by different federative entities and governed by their own legislation. This framework generates inefficiencies in resource allocation, increases compliance costs, and hinders tax planning, affecting investment decisions, pricing, and the organization of production chains (Varsano, 1996; Schoueri, 2018).

In response to this complex scenario, Constitutional Amendment No. 132/2023 introduces a significant overhaul of consumption taxation. This reform aims to modernize the tax system by reducing its complexity, tax cascading, and legal uncertainty, factors that have historically compromised business competitiveness and economic predictability. The proposal establishes a dual Value Added Tax (VAT) model, comprising the Contribution on Goods and Services (CBS), under the Union’s jurisdiction, and the Tax on Goods and Services (IBS), administered jointly by States, the Federal District, and Municipalities. This new model seeks to simplify the tax system, increase transparency, and align Brazil with international best practices (OECD, 2022). Studies by the OECD (2022) and IPEA (2021) indicate that efficient tax systems should be guided by the principles of simplicity, neutrality, and non-cascading. Furthermore, evidence suggests that VAT models can mitigate systemic problems and stabilize the tax burden, especially in sectors with complex production chains (Keen, 2020; European Commission, 2019).

Although the reform may bring improvements to the tax system, its implementation imposes relevant challenges on business management, especially during the transition period. The adaptation of internal processes, the restructuring of pricing strategies, and investments in systems and technology require greater planning capacity from companies. These challenges are particularly relevant in the electro-electronic sector, which is characterized by a high tax burden, frequently reduced operating margins, and significant sensitivity to cost variations. In this context, changes in taxation can directly affect the final price of products, overall profitability, and companies’ cash flow.

Given these considerations, understanding the implications of tax reform is crucial for strategic management and tax planning of companies, in addition to offering support for the formulation of public policies and decision-making in environments marked by regulatory uncertainty. This study, therefore, is justified by the need to analyze the possible impacts of Tax Reform on the tax management of companies in the electro-electronic sector, especially with regard to the tax burden, operational performance, and price formation. Therefore, the general objective of this work is to analyze such impacts through simulations with real data, comparing the current and proposed regimes, and to understand how the changes influence business decision-making in a context of tax transition.

2. Material and Methods

The present study adopted a methodological approach that combined quantitative and qualitative elements, characterizing itself as an exploratory and descriptive research. The central objective was to analyze the impacts of the Tax Reform, instituted by Constitutional Amendment No. 132/2023, on the tax management of companies in the electro-electronic sector. To this end, comparative simulations were carried out between the current tax model and the proposed consumption taxation system, based on the Tax on Goods and Services (IBS) and the Contribution on Goods and Services (CBS).

The nature of the research was predominantly documentary, based on the analysis of applicable tax legislation, including Constitutional Amendment No. 132/2023 and the complementary legislation of the Tax Reform. Additionally, studies and data from institutions such as the Brazilian Federal Revenue Service, the Institute of Applied Economic Research (IPEA), and the Organisation for Economic Co-operation and Development (OECD) were consulted, providing the theoretical and legal basis for the simulations (Gil, 2008).

The unit of empirical analysis consisted of a large company in the home appliance and consumer electronics sector, with international operations. The financial data used for the simulations were obtained from the company’s Standardized Financial Statements (DFP), referring to the fiscal years 2023 and 2024, made publicly available by the Securities and Exchange Commission (CVM). The company’s identification was preserved, in accordance with institutional guidelines.

The data collection procedure involved the survey and organization of the company’s financial information, complemented by the analysis of its explanatory notes. From this data, a standardized operational base was established for the simulations, allowing the construction of comparative scenarios and the isolation of the effects of tax changes.

The analysis flow comprised five main stages. Firstly, financial data was collected and organized. Secondly, the premises and tax parameters to be applied in each scenario were defined. Subsequently, the applicable taxes under the current model were applied, considering ICMS, IPI, PIS, and COFINS, along with their credit utilization rules.

In the fourth stage, the Tax Reform scenario was applied, considering the IBS and CBS, and the credit utilization percentage defined for the study. Finally, the results obtained in both scenarios were compared, focusing on the tax burden, pricing, operational margin, and cash flow, aiming to quantify the differences generated by the new system.

To ensure comparability between scenarios, the company’s main operational variables, such as cost structure, sales volume, and operating margin, were kept constant. This methodological strategy ensured that the differences observed in the simulations were predominantly attributed to changes in the taxation system.

The tax parameters, including rates and credit utilization percentages, were defined based on applicable legislation and premises established for the study. In the current model, an effective tax burden of approximately 39% of the final price and an average credit utilization of 73% were considered. For the Tax Reform scenario, a general rate of 28% for IBS and CBS was adopted, with an estimated credit utilization of 95%.

The calculations were performed by applying these tax parameters to the same operational base, allowing the estimation of debit, credit, and residual tax cost values in each scenario. Subsequently, the results were compared to identify the possible effects of the Reform on the tax burden and its economic and financial implications.

Additionally, a sensitivity analysis was performed, varying the rates considered in the Reform scenario (25%, 27%, 28%, and 30% for IBS and CBS). The objective was to evaluate how different tax conditions could influence the company’s profitability and cash flow results, providing a more comprehensive perspective on the potential impacts.

The qualitative approach, according to Minayo (2014), was employed complementarily to interpret the quantitative results. This interpretation sought to relate the simulated data to the characteristics of the electro-electronic sector, addressing price formation, tax credit management, operational complexity, and the possible effects on business competitiveness.

3. Results and Discussion

The section presents the results of simulations carried out based on the financial data of a company in the electro-electronic sector, for the fiscal year 2024, and on the established tax premises. The central objective was to compare the effects of the current tax model with the consumption taxation system proposed by Constitutional Amendment No. 132/2023. The analysis covered the tax burden, pricing, operating margin, and cash flow, relating the findings to the sector’s characteristics and the possible impacts on business management.

Premises and Parameters of the Simulation

To enable comparison between scenarios, the company’s main operational variables were kept constant, such as cost structure, sales volume, and operating margin. Tax parameters were defined based on applicable legislation and the premises established for the research. In the current tax model, the effective tax burden was estimated at approximately 39% of the final price, considering ICMS of 18%, IPI of 10%, PIS of 1.65%, and COFINS of 7.6%, with an average credit utilization of 73% on inputs.

For the Tax Reform scenario, a combined general rate of 28% was adopted for the Tax on Goods and Services (IBS) and the Contribution on Goods and Services (CBS), with an estimated credit utilization of 95% on inputs, reflecting the full non-cumulativeness foreseen. The company’s gross revenue analyzed for 2024 was R$ 17.798 billion, and net revenue was R$ 12.932 billion, with an operating margin of 7.82%. The company’s current tax regime is the “Lucro Real” (Actual Profit), with partial cumulativeness, which served as the basis for comparisons. These parameters were crucial for estimating tax debits and credits in each model.

Company Characterization and Database

The empirical analysis was based on the consolidated financial data of a large company in the home appliances and consumer electronics sector, with international operations and significant market share. The data were obtained from the Standardized Financial Statements (DFP) for the fiscal years 2024 and 2023. In 2024, the company showed net revenue growth of 12.57% and operating income (EBIT) growth of 8.52% compared to the previous year, totaling R$ 1.011 billion. Despite the absolute increase in EBIT, the operating margin recorded a slight reduction of 0.29 percentage points, from 8.11% in 2023 to 7.82% in 2024, indicating that the net revenue growth outpaced EBIT growth.

The company’s net profit in 2024 reached R$ 908.72 million, representing a significant increase of 260.7% compared to R$ 251.92 million in 2023. Consequently, the net margin also showed a substantial rise of 4.84 percentage points, moving from 2.19% in 2023 to 7.03% in 2024. These financial indicators served as the operational basis upon which the tax parameters were applied, enabling the construction of scenarios and the analysis of the reform’s effects on the tax burden and the company’s other economic-financial indicators.

Comparative Analysis of the Tax Burden in the Electro-electronic Sector: Current Model versus Tax Reform

The simulations revealed significant differences between the current tax model and the one proposed by the Tax Reform. In 2024, the analyzed company registered a consolidated gross revenue of R$ 17.798 billion and taxes on sales and services of R$ 3.528 billion, resulting in a net revenue of R$ 12.932 billion. These values were fundamental for the construction of the simulated scenarios, allowing the isolation of the effects of tax changes on the same operational base.

Decomposition of the tax burden in the current model

In the current tax model, the company’s consumption taxation primarily involves ICMS, IPI, PIS, and COFINS. The simulation indicated estimated tax debits of approximately R$ 5.562 billion and estimated credits of R$ 4.060 billion. This resulted in a residual tax cost of R$ 1.502 billion, which corresponds to 8.44% of the company’s gross revenue. The utilization of credits at 73% was a fundamental premise for these calculations, highlighting the portion of taxation that remains as an effective cost after credit offsetting.

The detailed breakdown of taxes in the current model revealed that IPI, with an average rate of 10%, generated a residual cost of R$ 192.2 million. ICMS, with a rate of 18%, resulted in R$ 648 million in residual cost. PIS and COFINS, with rates of 1.65% and 7.60% respectively, contributed R$ 79.30 million and R$ 365.20 million to the residual cost. These values demonstrate the partial cumulativeness of the current system, where part of the taxes is not fully recovered, directly impacting operational costs and product pricing.

The structural comparison between the current model and that of the Tax Reform highlights the proposed changes. In the current model, taxes such as ICMS, IPI, PIS, and COFINS operate under a partially cumulative regime, with incidence predominantly at the origin. The effective tax burden ranges between 35% and 40%, and the system is characterized by high complexity and low transparency. In contrast, the Tax Reform model, with IBS and CBS, foresees a full non-cumulative regime and destination taxation. The estimated tax burden is between 25% and 30%, with reduced complexity and high transparency, according to the research premises.

Impact of Tax Burden on Final Price

Consumption taxation is a determining factor in the final price formation of products in the electro-electronic sector. To evaluate this impact, a product with a base price of R$ 1,000.00 was used as a reference, keeping other operational characteristics constant. In the current tax model, the estimated final price for this product was R$ 1,390.00. In the Tax Reform scenario, considering the combined rate of 28% for IBS and CBS and greater credit utilization, the estimated final price was reduced to R$ 1,280.00.

This reduction represents a decrease of R$ 110.00 in the final product price, equivalent to approximately 7.9%. The results indicate that the expansion of non-cumulativeness in the proposed model tends to reduce the portion of taxes incorporated into operational costs, unlike the current model, where limitations on credit utilization generate a residual tax cost. However, the eventual reduction in tax cost does not necessarily imply a proportional reduction in the consumer price, as the company may choose to pass on part of the gain, preserve its margin, or combine both strategies.

Sensitivity Analysis of IBS and CBS Rates

To assess the influence of the combined IBS and CBS rate on the company’s results, four scenarios were simulated: 25%, 27%, 28% (base scenario), and 30%. In the 25% scenario, the estimated operating margin reached 10.82%, and the projected operating cash flow was R$ 2,767.89 billion. With the 27% rate, the operating margin was 8.82%, and the cash flow was R$ 2,509.26 billion. In the base scenario of 28%, the estimated operating margin was 7.82%, and the operating cash flow was R$ 2,379.94 billion.

In the scenario with a 30% tax rate, the operating margin decreased to 5.82%, and the estimated operating cash flow was R$ 2,121.31 billion. These results demonstrate that the change in the new tax system’s rate has relevant effects on the company’s profitability and cash generation. The reduction of the rate to 25% represents an increase of 3.0 percentage points in the operating margin compared to the base scenario, while the increase to 30% implies a reduction of 2.0 percentage points. Cash flow follows these variations, reinforcing the sensitivity of the results to the rate definition.

Business Level: Impact on Residual Tax Cost

The application of the dual VAT model parameters to the financial structure of the analyzed company, focusing on the residual tax cost, revealed a significant reduction. In the current tax model, the estimated residual tax cost was R$ 1.502 billion, equivalent to 8.44% of gross revenue. In the simulated scenarios of the Tax Reform, the residual tax cost varied between R$ 222.5 million (25% rate) and R$ 267.0 million (30% rate).

In the baseline scenario of 28% for IBS and CBS, the estimated residual tax cost was R$ 249.2 million, corresponding to 1.40% of gross revenue. This estimate represents a reduction of approximately R$ 1.253 billion compared to the current model, which is equivalent to 83.4%. The main reason for this reduction lies in the greater utilization of credits foreseen in the dual VAT, estimated at 95%, in contrast to the 73% of the current model. This effect can contribute to greater tax predictability and cash generation, although the impacts on prices, profitability, and investments depend on the company’s specific economic and operational conditions.

Case Study: Application of Tax Reform in the Commercialization Chain of the Electro-Electronic Sector

A case study simulated the impacts of the Tax Reform on the commercialization chain of electro-electronic products, involving industry, distributor, retail, and final consumer. For a product with a base price of R$ 1,000.00, the estimated final price in the current tax model was R$ 1,390.00. In the Tax Reform scenario, with a combined rate of 28% for IBS and CBS and greater use of credits, the estimated final price was reduced to R$ 1,280.00.

This reduction of R$ 110.00, equivalent to approximately 7.9%, demonstrates how the tax structure influences price formation along the chain. In the current model, limitations in credit utilization can incorporate part of the taxation into the costs of operations. In the dual VAT model, the expansion of non-cumulativeness tends to mitigate this effect. The results indicate that the dual VAT can reduce distortions in the supply chain and promote greater transparency in price formation, although the effective impact on the consumer price depends on the characteristics of each operation and the distribution of tax effects among the chain participants.

Impacts of Tax Reform on the Management of Companies in the Electro-electronic Sector

The implementation of CBS and IBS, according to Constitutional Amendment No. 132/2023, may significantly affect the management of companies in the electro-electronic sector. Pricing, cost management, and decision-making areas will be particularly impacted, given the complexity of the sector’s production chains and the high participation of consumption taxes. The expansion of non-cumulativeness and greater credit utilization, observed in the reduction of residual tax costs, may decrease the portion of taxes that currently remain in companies’ costs.

This change allows decisions related to pricing, costs, investments, and operational organization to more directly consider economic and productive factors, rather than being predominantly influenced by taxation effects. However, the transition will require attention to internal processes and integration between the tax, financial, and operational areas. The management of credits, tax costs, prices, and cash flow must be monitored in an integrated manner so that the company can evaluate the effects of the new model on its operations and adapt effectively.

Transition Period and Implementation of the New System

The implementation of the Tax Reform will occur gradually between 2026 and 2033, implying progressive changes in consumption taxation and the coexistence of taxes from the current model and the new ones. Companies will need to adapt their routines to the new IBS and CBS calculation rules, while maintaining procedures related to the current system. This transition will require adjustments in accounting, tax, and management systems, in addition to reviewing internal processes, pricing policies, and calculation procedures.

The training of the teams will be fundamental for the correct application of the new rules and for the reduction of errors during the model change. For the analyzed company, advance preparation will be crucial to monitor the effects of the new rules on tax credits, costs, prices, and cash flow. Points of attention include updating ERP systems, reviewing internal processes, planning cash flow, and monitoring regulatory changes. A gradual transition, if well managed, can reduce operational risks and facilitate adaptation, allowing the company to monitor the impacts of the Tax Reform as the new model is implemented.

Challenges and Opportunities of the New Tax Model

The implementation of the model based on the CBS and IBS, according to Constitutional Amendment No. 132/2023, may alter the form of consumption taxation, bringing significant effects to the management and competitiveness of companies in the electro-electronic sector. Among the main opportunities, the greater utilization of credits and the consequent reduction of cumulativeness stand out. In the simulations carried out, these factors contributed to the decrease in residual tax cost and positively impacted the operational margin, cash flow, and pricing of the analyzed company.

The standardization of rules could also simplify some tax procedures and reduce part of the existing complexity. Another potential effect is destination taxation, which can decrease the influence of tax factors on decisions about the location of operations and product distribution, giving greater weight to aspects such as logistical efficiency and proximity to consumer markets. On the other hand, the change in model presents challenges, such as the revision of fiscal and accounting systems, the adaptation of internal processes, and the training of teams, which will require time and resources. The review of tax incentives and current strategies may also be necessary.

Risks and Uncertainties

The main risks and opportunities identified in this study are related to the IBS and CBS rates, the utilization of credits, the regulation of the new system, and the necessary adaptations during the transition period. The sensitivity analysis showed that changes in rates can alter the results obtained in the simulations. For example, a combined rate of 25% for IBS and CBS would result in a residual tax cost of R$ 222.50 million, while 28% (base scenario) would lead to R$ 249.20 million, and 30% to R$ 267.0 million, with varied impacts on gross revenue.

The greatest use of credits represents an important opportunity to reduce tax costs and improve the efficiency of the production chain, with high probability and positive impact. However, the transition period and the adaptation of ERP systems are risk factors with medium impact and certain or high probability, requiring simultaneous adaptations of systems and processes. The change in price formation and cash flow management are also points of attention, with medium impact and high probability, demanding a review of pricing policies and monitoring the effects of the new model on credits and working capital. The regulation of the new system, with high probability and high impact, may require adjustments in the processes and premises of tax planning.

Economic-Financial Impacts on the Company

The Tax Reform may affect companies’ results, mainly due to changes in consumption taxation and greater credit utilization. In the current model, taxes are often incorporated into costs, influencing price formation. With the new system, the alteration in how credits are calculated and utilized may reduce part of the taxes that remain as a cost for the company. For the analyzed company, simulations indicated a reduction in residual tax cost under the Reform scenario, driven by greater credit utilization and the expansion of non-cumulativeness.

This reduction can directly reflect on costs and, consequently, on the company’s profitability. The sensitivity analysis showed that the results vary according to the considered rate, highlighting the importance of defining the IBS and CBS rates for tax and financial planning. Although price formation may be affected by the reduction in tax cost, the decision to pass this reduction on to the consumer will depend on factors such as operational costs, desired margin, competition, and commercial strategy. Thus, the economic-financial impacts of the Reform must be analyzed comprehensively, considering the effects on costs, prices, and profitability, and not just the tax burden.

Cash Flow Impacts

The Tax Reform may affect companies’ cash flow, mainly due to changes in the way taxes are collected and credits are utilized. One of the points that deserves attention is the *split payment* mechanism, which may separate the tax amount at the time of the transaction payment, directing it directly to collection. This measure can impact working capital, especially in companies that depend on greater cash availability to maintain their operations, requiring attention to financial projections and liquidity control during the transition period.

On the other hand, the greater utilization of credits and the possibility of refunding credit balances can reduce the impact of taxes on cash flow, benefiting companies that accumulate credits in certain operations, depending on the rules defined for their use and refund. In the simulations performed, the estimated operational cash flow varied significantly according to the considered rate, ranging from approximately R$ 2.768 billion in the 25% scenario to R$ 2.121 billion in the 30% scenario. This variation demonstrates that the adopted rate can have a direct impact on the resources available to the company, highlighting the need for joint monitoring by the tax and financial areas to manage cash availability during the transition.

Study Limitations

The results presented should be interpreted considering some methodological and operational limitations. The simulations used tax rates and credit utilization percentages defined in the research premises, which means that changes in these parameters or in future regulations may generate different results. The analysis was performed based on a single company in the electro-electronic sector, which limits the generalization of the results to other companies, as differences in size, operational structure, cost composition, tax regime, location, and supply chain may produce distinct impacts.

Financial data were obtained from the company’s public information, while some information necessary for the simulations was estimated based on the study’s premises. Simplifications were adopted to compare the two scenarios, without fully considering particularities such as tax benefits, special regimes, and different supply conditions. Regarding cash flow, the results depend on the premises used, and the dynamics of tax collection, credit utilization, and refund may vary according to applicable rules and the implementation of the new system. Another limitation is related to the transition period, which is gradual and depends on regulation, potentially altering the conditions considered in the simulations. Furthermore, the same operational structure was maintained in both scenarios, without considering possible strategic changes by the company in response to the new tax environment. Given these limitations, the results should be understood as estimates based on the research premises, and not as definitive projections of the company’s future performance.

In summary, the simulations performed indicated that the Tax Reform can generate relevant effects on the tax structure and the results of the analyzed company in the electro-electronic sector. The reduction of the residual tax cost, the decrease in the estimated final price of products, and the sensitivity of the operational margin and cash flow to the IBS and CBS rates were the central findings. These results demonstrate that the new model, with its full non-cumulativeness and destination taxation, has the potential to simplify processes, increase transparency, and promote greater fiscal efficiency, responding to the objective of analyzing the impacts of the reform on the tax management of companies in the electro-electronic sector.

4. Conclusion

This study analyzed the possible impacts of the Tax Reform, instituted by Constitutional Amendment No. 132/2023, on the tax management of companies in the electro-electronic sector, focusing on the tax burden, pricing, operating margin, and cash flow, through simulations with real data. A significant reduction in residual tax cost was verified, which went from R$ 1.502 billion in the current model to R$ 249.2 million in the baseline scenario of 28% for IBS and CBS, representing a decrease of 83.4%. The simulation of a representative product also indicated a reduction in the final price from R$ 1,390.00 to R$ 1,280.00. It was observed that the company’s operating margin and cash flow are sensitive to the IBS and CBS rates, with notable variations between the simulated scenarios. The study’s main contribution lies in demonstrating that the reform has the potential to simplify processes, increase transparency, and promote greater fiscal efficiency, strengthening tax management in sectors with high consumption tax burdens, such as the electro-electronic sector, driven by greater credit utilization.

However, the results should be interpreted considering some limitations, such as the dependence on the rates and percentages of credit utilization defined in the premises, and the fact that the analysis was performed based on a single company in the electro-electronic sector, which restricts generalization. The dynamics of tax collection and credit restitution, as well as the gradual transition period, may also alter the estimated results. For future studies, it is recommended to expand the analysis to other companies and sectors, incorporate more dynamic scenarios, and update the simulations as the regulation of the Tax Reform progresses, in order to deepen the understanding of its effects.

Bibliographic References

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ORGANIZAÇÃO PARA A COOPERAÇÃO E DESENVOLVIMENTO ECONÔMICO. 2022. Consumption tax trends 2022: VAT/GST and excise rates, trends and policy issues. Disponível em: https://www.oecd.org. Acesso em: 16 jan. 2026.

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VARSANO, R. 1996. A evolução do sistema tributário brasileiro ao longo do século: anotações e reflexões para futuras reformas. Disponível em: https://www.ipea.gov.br. Acesso em: 16 jan. 2026.

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

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