Tax Reform in the Hotel Sector: Planning Framework for Real Profit Companies

Leonardo Nezzo Volpatti; Regis Garcia

DOI: 10.22167/2675-6528-202603138

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 transition from the cumulative regime (PIS, COFINS, ISS) to the dual Value Added Tax (VAT), established by Constitutional Amendment No. 132/2023 and regulated by Complementary Law No. 214/2025, imposed structural challenges on the Brazilian hotel sector. The study aimed to analyze the financial impacts of this transition and propose a tax and strategic planning framework for companies under the Lucro Real regime. A quali-quantitative approach was adopted, combining documentary-normative analysis with financial scenario simulation. The scenarios were parameterized by sectoral data (FOHB) and structured according to the international accounting standard Uniform System of Accounts for the Lodging Industry (USALI). Three hotel profiles (Economy, Midscale, and Resort) were modeled to project the evolution of the effective tax burden between 2027 and 2033. The results showed that the 40% reduction in the reference rate did not guarantee uniform tax relief. The Economy Hotel, highly dependent on Simples Nacional suppliers, experienced an increase in its net tax burden under the full regime due to limitations in credit transfer. A “critical zone” of partial double taxation (2031-2032) was identified, requiring cash robustness from all profiles. Furthermore, the “B2B Paradox” was observed: although Midscale and Resort hotels showed a reduction in their net tax burden, the prohibition of credit for the acquirer (art. 283) increased the effective cost of corporate accommodation. It was concluded that competitiveness in the new regime will require active sourcing management, review of B2B pricing, and rigorous segregation of revenues, consolidating tax management as a central strategic pillar of hotel operations.

Keywords: Hospitality; Dual VAT; Tax Planning; Tax Reform; Scenario Simulation.

1. Introduction

The enactment of Constitutional Amendment No. 132/2023 marked the most profound alteration in the National Tax System since the 1988 Constitution. This new framework replaces a fragmented and dysfunctional model with a dual Value Added Tax (VAT), composed of the Tax on Goods and Services (IBS), with shared competence between States, the Federal District, and Municipalities, and the Social Contribution on Goods and Services (CBS), with Union competence. The uniformity of the system is guaranteed, as established by Article 149-B of the Federal Constitution (Brazil, 2023).

The previous tax model, characterized by the coexistence of taxes such as ICMS, ISS, IPI, PIS, and COFINS, substantially deviated from international standards of consumption taxation. Classical doctrine already warned that ICMS, for example, did not qualify as a true value-added tax, due to its calculation base and severe restrictions on crediting (Carrazza, 2023). Significant distortions were also generated by residual cumulativeness, impacting the burden on the production chain and the loss of international competitiveness (Derzi, 2024). In contrast, the reform was structured under the premise of neutrality, a constitutional principle expressed in Article 156-A, §1º, of the CF/88, which seeks to prevent the tax from influencing economic organization, investment decisions, or price formation, with its burden falling exclusively on the final consumer. To this end, the new system adopts full non-cumulativeness, overcoming the model of restricted physical credit and allowing credit on all acquisitions of goods and services, except for personal use or consumption (Schoueri, 2024; Brasil, 2023).

The services sector, historically subjected to a lower tax burden than industry due to the incidence of ISS (limited to five percent) and the cumulative PIS/COFINS regime (3.65%), was at the center of the tax reform debates. To mitigate the impact of the nominal VAT rate increase, Complementary Law No. 214/2025, in its Section II (Articles 277 to 283), established a specific regime for hotel, amusement park, and theme park services, setting a 40% reduction in the IBS and CBS rates for these operations (Brazil, 2025a).

However, while the reduction in the tax rate mitigates the impact on the final price for individual consumers, on the other hand, Article 283 of Complementary Law No. 214/2025 expressly prohibits the appropriation of IBS and CBS credits by the acquirer of hotel services. This prohibition transforms the IBS and CBS levied on accommodation into an unrecoverable cost for the acquiring company, representing a breach of the principle of full non-cumulativeness and the neutrality of the system (Pontes, 2025). Furthermore, Complementary Law No. 227/2026 introduced a relevant change by determining that the operations of supplying food and beverages by hotels will observe the rules related to the specific regime for bars and restaurants (Brazil, 2026), adding another layer of complexity to the sector’s tax management. The dependence on suppliers opting for the Simples Nacional aggravates the situation, limiting the transfer of credits and potentially increasing the net tax burden for some hotel profiles, such as the economy segment, as pointed out in the approved summary.

Given this complex normative scenario and the significant structural and operational changes imposed on the hotel sector, proactive planning becomes imperative to mitigate risks and optimize the tax burden. Thus, the present work has as its general objective to develop a tax planning and transition management framework for hotel companies classified under the “Lucro Real” (Real Profit) regime, analyzing the financial and operational impacts arising from the implementation of the dual VAT (IBS and CBS) established by Constitutional Amendment No. 132/2023 and regulated by Complementary Law No. 214/2025. The study seeks to provide practical guidelines for the sector’s adaptation to the new rules of non-cumulativeness, specific regimes, and ancillary obligations, mitigating risks and optimizing the tax burden during the transition period (2027-2033).

2. Material and Methods

This research was characterized as a study of an applied nature, adopting a quali-quantitative approach. The methodology was structured in two complementary stages: documentary-normative analysis and financial scenario simulation. This choice was justified by the need to interpret the innovations brought by Constitutional Amendment No. 132/2023 and Complementary Law No. 214/2025, as well as to measure their practical impacts on the financial management of companies in the hotel sector, meeting the rigor required for research in Tax Management.

In the first stage, of a qualitative nature, a bibliographic and documentary review was carried out. The analysis corpus was composed of the primary legislation of the tax reform, including Constitutional Amendment No. 132/2023, Complementary Law No. 214/2025, and Complementary Law No. 227/2026. These documents were compared with classic tax doctrine (Carrazza, 2023; Schoueri, 2024) and with recent scientific articles published in high-impact journals (Breyner, 2024; Peroto and Conte, 2025). The analysis focused on the evolution of the non-cumulative principle, the transition from physical credit to broad financial credit, and the implications of the specific regime for the hotel industry, according to articles 277 to 283 of Complementary Law No. 214/2025.

The second stage, quantitative and applied in nature, consisted of building a financial model. The objective was to simulate the evolution of the effective tax burden for companies under the “Lucro Real” (Actual Profit) regime during the transition period to the dual Value Added Tax (VAT), covering the years 2027 to 2033. To ensure the external validity of the simulation, the scenarios were parameterized with real sectoral data. This data was extracted from the “Hotelaria em Números 2024” (Hospitality in Numbers 2024) report by the Brazilian Hotel Operators Forum (FOHB, 2024).

The financial modeling structure followed the international accounting standard Uniform System of Accounts for the Lodging Industry (USALI) (HFTP, 2024). Three hotel profiles representative of the Brazilian market were modeled: Economy Hotel, Midscale Hotel, and Resort. The premises for each profile, such as gross annual revenue, average daily rate, pension plan, customer profile, percentage of Simples Nacional suppliers, and taxable operating costs, were detailed for each scenario. These premises served as the basis for tax calculations.

The modeling incorporated tax variables specific to the transition. The projected reference rate of 28%, according to estimates from the Ministry of Finance, and the 40% reduction for hotel services, established in article 281 of Complementary Law No. 214/2025, were considered. Also included was the calibration schedule for the Goods and Services Tax (IBS) rates, according to article 372 et seq., and the limitation on credit transfers by suppliers opting for the Simples Nacional, provided for in article 49, §9°, of Complementary Law No. 214/2025. The scenario analysis followed the scenario planning methodology recommended by PwC (2026) and Fundação Dom Cabral (FDC, 2025).

Based on the findings from the documentary analysis and the simulations performed, a strategic decision-making framework was developed. This framework was designed for hotel top management and structured according to the tax transformation methodologies proposed by consultancies such as Deloitte (2025), EY (2025), and KPMG (2025). The framework includes three areas of action: Governance and Processes, Supply Chain and Operations, and Pricing and Market. A roadmap of critical decisions, year by year, was presented for each hotel profile during the transition period.

3. Results and Discussion

The transition to the dual Value Added Tax (VAT), established by Constitutional Amendment No. 132/2023 and regulated by Complementary Law No. 214/2025, imposes complex structural and financial challenges on the Brazilian hotel sector. The impact analysis revealed that the 40% reduction in the reference rate for hotel services does not translate into uniform tax relief for all hotel profiles, depending critically on cost structure, customer profile, and reliance on suppliers opting for Simples Nacional. The research identified a “critical zone” of partial double taxation and the “B2B Paradox,” which will require proactive tax and strategic management to maintain competitiveness.

General Rules of Transition and Schedule

The implementation schedule for the tax reform, which extends from 2026 to 2033, represents an unprecedented adaptation period. In 2026, the “test year”, the CBS and IBS are introduced with symbolic rates of 0.9% and 0.1%, respectively, while current taxes remain unchanged, according to article 372 of LC 214/2025 (Brazil, 2025a). This initial phase aims to test the collection systems and new ancillary obligations, such as the Declaration of Specific Regimes (DeRE), with the compensation of the CBS amount collected against the due COFINS to mitigate financial impacts.

The first significant structural change occurs in the 2027-2028 biennium, with the extinction of PIS and COFINS, replaced by the CBS at its full reference rate, estimated at 8.8%. The IPI is also reduced to zero, except for products from the Manaus Free Trade Zone (Brazil, 2023). The IBS maintains its test rate of 0.1%, and the ICMS and ISS continue to be charged in full. For the hotel sector, this period already demands the adaptation of pricing systems and the review of the supply chain, as the CBS will apply to a broad base, allowing financial credits on inputs that previously did not generate credit rights under the restricted non-cumulative regime (Deloitte, 2025).

The most challenging period of the transition covers the years 2029 to 2032, when the IBS gradually replaces the ICMS and ISS. The legislation foresees a proportional reduction in the rates of the old taxes and a corresponding increase in the IBS, starting with 10% in 2029 and advancing to 40% in 2032 (Brasil, 2025a). During this four-year period, hotel companies will have to calculate and pay the ISS with decreasing rates and, simultaneously, the IBS with increasing rates on the same tax base, in addition to the CBS already in full effect. This coexistence of regimes reaches its peak of operational complexity in the “critical zone” of 2031-2032, requiring rigorous systemic controls to avoid double taxation and ensure the correct appropriation of credits (KPMG, 2025).

Starting in 2033, ICMS and ISS will be definitively extinguished, consolidating the full regime of the Dual VAT. The monthly calculation formula, provided for in article 45 of LC 214/2025, consolidates all of the taxpayer’s establishments into a single calculation, simplifying management for hotel chains compared to the previous regime. A detailed understanding of this timeline is fundamental for hotel top management, serving as a basis for long-term strategic decisions, such as investments, contract renegotiations, and corporate restructuring (FDC, 2025).

Specific Regime for Bars and Restaurants and its Impact on the Hotel Sector

Constitutional Amendment No. 132/2023 authorized specific regimes for various sectors, including hotels and restaurants (Brazil, 2023). Complementary Law No. 214/2025 regulated these guidelines, but the intersection between hotel activity and the supply of food and beverages (F&B) generated notable interpretive and operational complexity. The specific regime for bars and restaurants, regulated in articles 273 to 276 of CL 214/2025, grants a 40% reduction in IBS and CBS rates for the supply of food and beverages prepared on the premises (Brazil, 2025a).

However, this reduction has important limitations. §1 of article 273 expressly excludes alcoholic beverages from the benefit of the reduced rate, subjecting them to the full reference rate. Additionally, §2, item III, prohibits the application of the reduction when the acquirer is a legal entity under contract, directly impacting the supply of corporate meals and business events in hotels (Brazil, 2025a). Complementary Law No. 227/2026 added a layer of complexity by determining that A&B revenues in hotels will follow the regime of bars and restaurants, and not the specific hotel regime (Brazil, 2026).

This normative segregation creates an operational duality within the same establishment, requiring that the lodging revenue (daily rate) be taxed by the rules of articles 277 to 283, while the A&B revenue follows articles 273 to 276. The practical consequences are profound for the modeling of hotel packages. In a full-board resort, for example, the revenue must be broken down into distinct tax components: lodging rate (40% reduction, prohibition of buyer’s credit), prepared food (40% reduction, except for B2B under contract), and alcoholic beverages (full rate of 28%) (Brazil, 2025a).

This complexity requires detailed parameterization of ERP systems and a review of electronic fiscal document issuance procedures. For strategic hotel management, the duality of regimes imposes the need to review the pricing structure and package modeling. Pricing must reflect the effective tax burden of each service component, and the optimization of this composition, combined with correct system parameterization, becomes a critical competitive differentiator during and after the transition period (Deloitte, 2025).

The Hosting Regime and the Impact of Simples Nacional on the Credit Chain

The specific hotel regime, established in articles 277 to 283 of Complementary Law nº 214/2025, seeks to mitigate the impact of the Dual VAT on a labor-intensive sector with high price elasticity. Article 278 defines hotel services as the provision of temporary accommodation and services included in the accommodation fee, with article 281 establishing a 40% reduction in the IBS and CBS rates, resulting in a nominal burden of 16.8% (Brazil, 2025a). However, article 283 imposes a severe restriction: the purchaser of hotel services will not be able to appropriate IBS and CBS credits, making the tax an unrecoverable cost for the corporate consumer (Brazil, 2025a).

For the supplier hotel, Article 282 guarantees the right to the full appropriation of credits related to its acquisitions of goods and services, enshrining the principle of full non-cumulativeness (Brazil, 2025a). However, the effectiveness of this right is substantially compromised when the hotel acquires inputs from companies opting for Simples Nacional, a common reality in the hotel supply chain, especially in small and medium-sized enterprises in regional tourist destinations. The relationship between the regular regime of the Dual VAT and Simples Nacional was paradigmatically altered by the reform.

Article 41, §3 of LC 214/2025 allows micro and small enterprises opting for Simples Nacional to choose to pay the IBS and CBS under the regular regime, segregating them from the Simples Nacional Collection Document (DAS) (Brazil, 2025a). If the supplier makes this choice, they transfer the full credit (full rate) to the acquiring hotel. However, if the supplier maintains unified collection in the DAS, the credit rule changes drastically, according to Article 49, §9, item II, of LC 214/2025.

In this scenario, the appropriable credit will be strictly equivalent to the amount of IBS and CBS effectively paid by the Simples Nacional supplier through the DAS (Brazil, 2025a). This implies that, instead of appropriating a credit of 28% (full reference rate), the hotel will appropriate a credit corresponding to the effective rate of Simples Nacional, which can vary between 2% and 8% depending on the supplier’s revenue bracket. This asymmetry generates a “credit loss” in the production chain that can reach 21 percentage points on each acquisition.

The situation is even more serious for acquisitions by Individual Microentrepreneurs (MEI) and Nanoentrepreneurs. Article 23, §4º, of LC 214/2025 establishes that MEI acquisitions do not generate the right to IBS and CBS credit for the acquirer (Brazil, 2025a). Similarly, the Nanoentrepreneur, a figure created by Article 26, item IV, is not an IBS/CBS contributor and therefore does not transfer any credit (Brazil, 2025a). For hotels that depend on these suppliers for maintenance services, gardening, or artisanal products, this prohibition represents a direct increase in operational costs.

Faced with this scenario, supply chain management transcends the purely logistical and purchasing function, becoming a lever for strategic tax planning. The Total Cost of Ownership analysis of an input must incorporate the variable of transferred tax credit, according to EY methodologies (2025). A supplier under Simples Nacional with a lower nominal price may, in reality, be more costly for the hotel than a supplier under the regular regime with a higher price, due to the loss of financial credit. Article 41, §5º, of LC 214/2025 also provides for a two-fiscal-year quarantine for those who opt to return to unified collection through DAS, which must be considered when guiding suppliers.

From Full Non-Cumulativeness to Financial Credit and the Split Payment Mechanism

The essence of the new dual VAT lies in the transition from the physical credit model, characteristic of ICMS and IPI, to the broad financial credit model. In the previous regime, the appropriation of credits depended on exhaustive jurisprudential discussions about the concept of “input”, as evidenced in the judgment of REsp 1.221.170/PR by the Superior Court of Justice (Brazil, 2018). Constitutional Amendment No. 132/2023 overcame this limitation by instituting full non-cumulativeness, determining that the tax will be non-cumulative, offsetting the amount due against the amount charged on “all transactions in which the acquirer is of tangible or intangible assets, including rights, or services”, with the exception only of acquisitions for personal use or consumption (Brazil, 2023).

Complementary Law No. 214/2025 regulated this guarantee in its Article 47, establishing that the taxpayer subject to the regular regime may appropriate IBS and CBS credits when the debts related to the operations in which they are the acquirer are extinguished. This is the consecration of the financial credit conditioned to payment, a substantial innovation compared to the ICMS book-entry credit (Brazil, 2025a). Article 47, §10, guarantees that operations with reduced rates do not lead to the reversal of credits from acquisitions, which is particularly relevant for the hotel sector, whose sales are taxed at 16.8%, but whose inputs can generate credits at the full rate of 28%.

To enable this systematic approach without burdening companies’ cash flow with long waiting periods for crediting, LC 214/2025 introduced the split payment mechanism, regulated in its articles 31 to 35. Through this instrument, at the time of the financial settlement of the transaction, the amount corresponding to IBS and CBS is segregated and collected directly into public coffers, while the supplier receives only the net amount of the operation (Brazil, 2025a). Split payment acts as a guarantor of non-cumulativeness, ensuring that the tax has been effectively paid and authorizing immediate crediting by the acquirer (Peroto and Conte, 2025).

LC 214/2025 provides for three payment split modalities: the intelligent, the simplified, and collection by the acquirer (art. 36). For the hotel sector, payment split will radically alter treasury management, as the hotel will no longer receive the gross amount of sales paid by electronic means, receiving only the net amount (discounted by 16.8% of IBS/CBS). The finance department must recalibrate cash flow and working capital projections, especially for installment sales, where tax collection may occur before the actual receipt of subsequent installments (Conrado, 2025).

Numerical Simulations: Evolution of the Effective Tax Burden (2027-2033)

To make the effects of the transition tangible, numerical simulations were developed for three hotel profiles: Economy, Midscale, and Resort. The analysis projected the evolution of the effective tax burden year by year, considering the calibration schedule of the rates and the differentiated impact of Simples Nacional suppliers. The calculation logic followed the formula for determination provided for in article 45 of LC 214/2025, which combines total debits with financial credits, adjusted by the proportion of suppliers in Simples Nacional. For the transition years (2029-2032), the effective tax burden results from the weighted sum between the old regime (ISS + PIS/COFINS, with decreasing rates) and the new regime (IBS + CBS, with increasing rates), according to the schedule in article 372 of LC 214/2025 (Brazil, 2025a).

Scenario 1: Budget Hotel / Inn

The Economic Hotel, with annual gross revenue of R$ 24,000,000 and an average daily rate of R$ 300, operates on a half-board basis (breakfast included). Revenue composition is 80% from accommodation (R$ 19,200,000) and 20% from F&B (R$ 4,800,000). Taxable operating costs total R$ 9,120,000 (38% of revenue), and 100% of F&B suppliers are in the Simples Nacional regime. Under the previous regime, the net tax burden was R$ 2,252,400, equivalent to 9.36% of gross revenue.

In the full regime (2033), IBS/CBS debts on accommodation and F&B total R$ 4,032,000. However, financial credits are severely limited by the dependence on suppliers in the Simples Nacional. F&B inputs (R$ 3,244,800) generate credits of only R$ 227,136 (Simples effective rate of 7%), while other inputs (R$ 5,875,200) generate credits of R$ 1,421,856 (full rate of 28% adjusted by the proportion of regular suppliers). The annual loss of credits due to Simples suppliers reaches R$ 230,112. The net tax burden in the full regime is R$ 2,383,008, equivalent to 9.91% of gross revenue, representing an increase of 0.55 percentage points compared to the previous regime. This demonstrates that the high dependence on Simples Nacional suppliers nullifies the benefit of the reduced rate.

Scenario 2: Midscale Hotel

The Midscale Hotel presents gross annual revenue of R$ 100,000,000, with an average daily rate of R$ 800 and a half-board plan with F&B charged separately. Revenue is divided into 65% from accommodation (R$ 65,000,000) and 35% from F&B and events (R$ 35,000,000). Taxable operating costs total R$ 40,000,000 (40% of revenue), with 50% of F&B suppliers under the Simples Nacional regime. Under the previous regime, the net tax burden was R$ 10,287,500, equivalent to 10.29% of gross revenue.

In the full regime (2033), IBS/CBS debits on accommodation and F&B total R$ 16,800,000. Financial credits are partially limited by the proportion of Simples Nacional suppliers. The annual loss of credits due to Simples suppliers reaches R$ 838,950. The net tax burden in the full regime is R$ 8,670,000, equivalent to 8.67% of gross revenue, representing a reduction of 1.62 percentage points compared to the previous regime. However, the simulation revealed the “B2B Paradox”.

Although the Midscale Hotel shows a reduction in its net tax burden, the prohibition of credit for the acquirer (Article 283 of LC 214/2025) eliminates a historical competitive advantage. Under the previous regime, corporate clients could appropriate PIS/COFINS credits (9.25%) on the accommodation expense, reducing their effective cost. In the new regime, IBS and CBS become unrecoverable costs, increasing the effective cost of corporate accommodation by up to 9.25 percentage points. For the Midscale Hotel, whose revenue depends 60% on the B2B segment, this distortion requires a profound review of the pricing strategy (Pontes, 2025).

Scenario 3: Resort

The Resort presents an annual gross revenue of R$ 250,000,000, with an average daily rate of R$ 1,500 and full board (breakfast, lunch, and dinner included), in addition to SPA and entertainment services. The revenue composition is divided into 55% accommodation (R$ 137,500,000), 35% F&B (R$ 87,500,000), and 10% complementary services (SPA, recreation, and events, R$ 25,000,000). Taxable operating costs total R$ 112,500,000 (45% of revenue), with only 20% of F&B suppliers in the Simples Nacional. Under the previous regime, the net tax burden was R$ 19,843,750, equivalent to 7.94% of gross revenue.

In the full regime (2033), IBS/CBS debits on accommodation, F&B, and complementary services total R$ 44,800,000. Recreational and aesthetic services do not benefit from the 40% reduction, being taxed at the full rate of 28% (article 57, I, “f”, LC 214/2025). Financial credits are robust, given that 80% of suppliers are in the regular regime. The annual loss of credits from Simples suppliers reaches R$ 1,198,500. The net tax burden in the full regime is R$ 16,225,000, equivalent to 6.49% of gross revenue, representing a reduction of 1.45 percentage points compared to the previous regime. The Resort, with its lower dependence on Simples Nacional suppliers and a broad base of financial credits, is the biggest beneficiary of the reform.

Comparative Synthesis of the Three Scenarios

The simulation results reveal three strategic findings. Firstly, the Budget Hotel, with 100% of its F&B suppliers in Simples Nacional, is the only profile that experiences an increase in tax burden under the full regime, going from 9.36% to 9.91% (+0.55 p.p.). The loss of credits estimated at R$ 230,112 annually, resulting from the limitation of article 49, §9°, completely nullifies the benefit of the reduced rate. Paradoxically, although its absolute loss of credits is the smallest, the relative impact on the effective burden is the largest (+0.96 p.p.), due to its significantly lower gross revenue.

Secondly, all hotel profiles will experience a “critical zone” between 2031 and 2032. In this biennium, the tax burden will temporarily exceed the level of the previous regime, due to the coexistence of the increased IBS with the residual ISS. For the Economy Hotel, the burden reaches 10.84% in 2032, for Midscale, 10.47%, and for Resort, 7.39%. This transition phase will require cash robustness and rigorous management of the financial flow of hotel companies, configuring the period of greatest financial risk of the decade.

Third, the study highlighted the “B2B Paradox” in the hotel sector. Although Midscale and Resort hotels show a reduction in their net tax burden under the full regime (1.62 pp and 1.45 pp respectively), the prohibition of tax credits for the purchaser of accommodation services (Article 283 of LC 214/2025) eliminates a historical competitive advantage. The effective cost of accommodation for corporate clients will increase by up to 9.25 percentage points, requiring hotels to use the margin generated by the reduction of their own tax burden to subsidize discounts on corporate rates, under penalty of losing market share. For Resorts, the absolute loss of credits is the largest (R$ 1,198,500), but the relative impact is diluted by the scale of the operation (+0.48 pp).

Simplified Income Statements (USALI Standard)

The simplified Income Statements (DRE), structured according to the international accounting standard Uniform System of Accounts for the Lodging Industry (USALI) (HFTP, 2024), highlight the premises of financial modeling. The Resort, for example, presents the highest proportion of taxable operating costs in relation to revenue (45%), which, combined with low dependence on suppliers under Simples Nacional (20%), results in a significantly broader financial credit base. In contrast, the Economy Hotel, despite having the lowest proportion of taxable costs (38%), suffers from the almost total loss of credits on F&B purchases, as 100% of its suppliers in this category are under Simples Nacional. This structural asymmetry explains why the tax reform disproportionately benefits larger hotels with more professionalized supply chains.

It should be noted that payroll, which represents between 25% and 30% of gross revenue in the three scenarios, does not generate the right to IBS and CBS credit, as labor remuneration does not constitute a taxable event for these taxes. This characteristic is particularly relevant for the hotel sector, which is labor-intensive. Under the previous regime, payroll also did not generate PIS/COFINS credits, so in this specific aspect, the reform does not alter the sector’s dynamics. However, the expansion of the credit base on other inputs (energy, maintenance, linens, outsourced services) partially compensates for this limitation, especially for larger hotels with suppliers under the regular regime (EY, 2025).

Ancillary Obligations and Compliance During the Transition

The transition to the Dual VAT imposes a profound restructuring of ancillary obligations. The coexistence of two tax systems during the period from 2027 to 2032 will require hotels to simultaneously maintain controls related to the old regime (ISS, ICMS) and the new regime (IBS, CBS), with direct implications for the parametrization of ERP systems, the issuance of electronic tax documents, and accounting records (KPMG, 2025). Starting in 2026, the Declaration of Specific Regimes (DeRE) will be introduced as a transitional ancillary obligation, requiring hotels to declare, in electronic format, the composition of their revenues by type of operation, the cost structure, and the projected credits under the new regime (Brazil, 2025a).

The Electronic Invoice (NF-e) and the Electronic Service Invoice (NFS-e) will receive new mandatory fields to itemize the IBS, the CBS, and, when applicable, the Selective Tax (IS). For the hotel sector, the complexity is amplified by the need to segregate, in the same fiscal document, components subject to different tax regimes: the lodging daily rate, food, alcoholic beverages, and recreational services. Inadequate parameterization of NF-e issuance systems may result in tax assessments, denial of credits by the buyer, and overpayment of taxes (Deloitte, 2025).

The monthly calculation of IBS and CBS will follow the formula provided in Article 45 of LC 214/2025, which consolidates all of the taxpayer’s establishments into a single calculation. However, during the transition (2029-2032), the coexistence of municipal ISS with state/municipal IBS will require parallel controls, temporarily increasing operational complexity. The implementation of split payment, provided for in Articles 31 to 35 of LC 214/2025, will add a layer of automation to the collection process, automatically segregating the amount corresponding to IBS and CBS at the time of financial settlement of the transaction. This mechanism will require the integration of hotel management systems with payment systems and with the IBS/CBS calculation platform, generating a cash flow mismatch for installment sales that should be anticipated by the treasury (Peroto and Conte, 2025).

Strategic Decision-Making Framework for the Transition (2027-2033)

The transition to VAT Dual requires hotel top management to adopt a proactive strategic stance, transcending a purely accounting view. Based on the tax transformation methodologies of consultancies such as Deloitte (2025), EY (2025), and KPMG (2025), and on the precepts of corporate finance from Fundação Dom Cabral (FDC, 2025), a strategic decision-making framework structured around three pillars is proposed: Governance and Processes, Supply Chain and Operations, and Pricing and Market.

In the Governance and Processes axis, the priority is the immediate establishment of a multidisciplinary Working Group (WG) dedicated to Tax Reform, under the CFO’s leadership. This WG will be responsible for mapping the specific impacts of the reform, coordinating the parameterization of ERP systems, and training internal teams. Continuous training is fundamental, as the coexistence of tax regimes will require in-depth knowledge of the old and new rules (KPMG, 2025). The rigorous segregation of accommodation revenues (subject to a 40% reduction) and F&B revenues (subject to the bars and restaurants regime) becomes the foundation for tax compliance and tax burden optimization.

For the Economic Hotel, the 2027 phase (end of PIS/COFINS, start of CBS) requires mapping Simples Nacional suppliers and initiating an orientation program for them to opt for the regular regime (Article 41, §3°). In 2028 (preparation for IBS), the gradual replacement of suppliers and the exchange of MEIs and Simples companies that did not opt for the regular regime are crucial. From 2029 to 2030 (start of IBS transition), the gradual tariff pass-through of cost increases to the average daily rate, monitoring demand elasticity, is fundamental. In the “critical zone” of 2031-2032, strict cash flow management and the postponement of non-essential Capex are necessary due to partial double taxation.

In the Supply Chain and Operations axis, contract review is imperative. Long-term contracts with outsourced service providers (cleaning, security, laundry) must include clauses for price renegotiation based on changes in the tax burden and credit transfer (Deloitte, 2025). The decision between outsourcing or internalizing (verticalizing) activities, such as food handling or laundry, should be re-evaluated from the perspective of full financial credit. The verticalization of services such as in-house bakery and pastry shops becomes highly attractive, as all basic inputs will generate full financial credits, reducing the Cost of Goods Sold (COGS) (EY, 2025).

For the Midscale Hotel, in 2027, the review of corporate contracts (B2B) and negotiation to mitigate the impact of credit sealing (article 283) on renewals are essential. In 2028, the restructuring of distribution channels, evaluating the tax impact of OTA commissions and encouraging direct bookings, is a priority. From 2029 to 2030, the optimization of F&B, reviewing restaurant menus and suppliers to maximize credits under the bars/restaurants regime, is crucial. In the “critical zone” of 2031-2032, the implementation of Split Payment and the adaptation of financial systems for automatic withholding are fundamental to avoid fines.

On the Pricing and Market axis, the review of the commercial strategy must anticipate the impact of article 283 of LC 214/2025. As corporate clients (B2B) will not be able to claim credits on accommodation expenses, the effective cost of these trips will increase. The application of McKinsey’s Pricing Advantage methodology (2025) suggests that hotels with strong dependence on the corporate segment will need to absorb part of this impact in their margins or offer value-added counterparts to maintain competitiveness. Simultaneously, the commercial strategy must focus on expanding the leisure segment (B2C), which is not affected by the credit prohibition (Pontes, 2025).

For the Resort, in 2027, the systemic segregation of revenues and the ERP parameterization to separate lodging (40% reduction) from F&B and recreational services are crucial. In 2028, the verticalization analysis, assessing the feasibility of internalizing laundry, baking, and pastry operations to maximize credits, is important. From 2029 to 2030, package management and the review of All Inclusive package pricing to reflect the mixed load (lodging versus F&B versus alcoholic beverages) are fundamental. In the “critical zone” of 2031-2032, maximizing capital credits and accelerating the appropriation of credits for renovations and modernizations before the extinction of ICMS/ISS are strategic.

In 2033, under the full regime, the Economy Hotel must consolidate the new supplier network, operating exclusively with partners integrated into the regular regime. The Midscale Hotel must focus on a new market positioning and consolidate adjusted B2B rates, with a focus on corporate loyalty programs. The Resort, in turn, can seek margin expansion, using the effective reduction in tax burden (-1.45 p.p.) for reinvestment in infrastructure and premium services. These guidelines provide a structured roadmap for controllers and CFOs in the hotel sector to navigate the complexity of the transition, transforming the regulatory challenge into a sustainable competitive advantage.

In summary, the research demonstrated that the tax reform in the hotel sector will not result in uniform impacts, with the Economy Hotel facing an increase in the tax burden due to its dependence on Simples Nacional suppliers. The identification of the “critical zone” of partial double taxation between 2031 and 2032 highlights the need for cash robustness for all profiles. Additionally, the “B2B Paradox” shows that, although Midscale and Resort hotels may have their net burden reduced, the prohibition of tax credits for corporate clients will increase the effective cost of accommodation, requiring a strategic review of pricing and sourcing management. The proposed framework offers a path for hotel top management to adapt to this new scenario, transforming tax management into a central strategic pillar of the operation.

4. Conclusion

This study aimed to analyze the financial impacts of the transition to the dual Value Added Tax (VAT) in the Brazilian hotel sector and to propose a tax and strategic planning framework for companies under the “Lucro Real” regime. Through a quali-quantitative approach, which combined documentary-normative analysis with financial scenario simulation, it was found that the 40% reduction in the reference rate did not guarantee uniform tax relief for all hotel profiles. It was identified that the Economy Hotel, with high dependence on “Simples Nacional” suppliers, experienced an increase in the net tax burden in the full regime, resulting from the limitation in credit transfer. It was also observed the existence of a “critical zone” of partial double taxation between the years 2031 and 2032, a period that will demand cash robustness from hotel companies.

Additionally, the “B2B Paradox” was observed: although Midscale and Resorts hotels showed a reduction in their net tax burden, the prohibition of credit for the acquirer increased the effective cost of corporate lodging. The proposed tax planning and transition management framework offers a structured roadmap for hotel top management to navigate the complexity of the transition. Its main contribution lies in providing practical guidelines for the sector’s adaptation to the new non-cumulative rules, specific regimes, and ancillary obligations, mitigating risks and optimizing the tax burden. Competitiveness in the new regime, therefore, will require active sourcing management, review of B2B pricing, and rigorous segregation of revenues, consolidating tax management as a central strategic pillar of hotel operations.

Bibliographic References

Brasil. 2023. Emenda Constitucional nº 132, de 20 de dezembro de 2023. Altera o Sistema Tributário Nacional. Diário Oficial da União, Brasília, DF, Brasil.

Brasil. 2025a. Lei Complementar nº 214, de 15 de janeiro de 2025. Institui o Imposto sobre Bens e Serviços (IBS), a Contribuição sobre Bens e Serviços (CBS) e o Imposto Seletivo (IS). Diário Oficial da União, Brasília, DF, Brasil.

Brasil. 2026. Lei Complementar nº 227, de 10 de março de 2026. Altera a Lei Complementar nº 214/2025 para dispor sobre o regime de bares e restaurantes. Diário Oficial da União, Brasília, DF, Brasil.

Brasil. Superior Tribunal de Justiça [STJ]. 2018. Recurso Especial nº 1.221.170/PR. Relator: Ministro Napoleão Nunes Maia Filho. Primeira Seção. Julgado em 22 fev. 2018. DJe 24 abr. 2018.

Breyner, F. 2024. Dogmática do crédito físico versus crédito financeiro no novo IVA brasileiro. Revista Direito Tributário Atual 53: 112-135.

Carrazza, R.A. 2023. ICMS. 18ed. Malheiros, São Paulo, SP, Brasil.

Conrado, M. 2025. Desafios de Implementação do Split Payment no Brasil: Uma análise comparada. Dissertação (Mestrado em Direito). Fundação Getulio Vargas, São Paulo, SP, Brasil.

Deloitte. 2025. Adequação à Reforma Tributária: Da análise aprofundada do seu negócio à operação da transição. Deloitte Brasil, São Paulo, SP, Brasil.

Derzi, M.A.M. 2024. Distorções da não cumulatividade no ICMS e a transição para o IVA europeu. p. 89-115. In: Schoueri, L.E. (Coord.). Direito Tributário Contemporâneo. Dialética, São Paulo, SP, Brasil.

Ernst & Young [EY]. 2025. Tax Is Transforming: the time to prepare is now. EY Global, London, UK.

Fundação Dom Cabral [FDC]. 2025. Finanças Corporativas: Decisões estratégicas e geração de valor na Reforma Tributária. Fundação Dom Cabral, Nova Lima, MG, Brasil.

Fórum de Operadores Hoteleiros do Brasil [FOHB]. 2024. Hotelaria em Números 2024. FOHB/JLL, São Paulo, SP, Brasil.

Hospitality Financial and Technology Professionals [HFTP]. 2024. Uniform System of Accounts for the Lodging Industry (USALI). 12ed. HFTP, Austin, TX, EUA.

KPMG. 2025. Reforma Tributária 2025: 5 passos essenciais para sua empresa se preparar. KPMG Brasil, São Paulo, SP, Brasil.

McKinsey & Company. 2025. Strategic Pricing Lessons For Travel Volatility. McKinsey Insights, New York, NY, EUA.

Peroto, M.; Conte, R. 2025. Split payment no contexto brasileiro: Retenção automática e impacto no fluxo de caixa. Revista Direito Tributário Atual 55: 88-110.

Pontes, E. 2025. Reforma tributária e os gastos com hotelaria: equívocos e distorções nas regras de não cumulatividade plena. Consultor Jurídico (ConJur). Disponível em: https://www.conjur.com.br/2025-set-20/reforma-tributaria-e-os-gastos-com-hotelaria-equivocos-e-distorcoes-nas-regras-de-nao-cumulatividade-plena/. Acesso em: 22 abr. 2026.

PricewaterhouseCoopers [PwC]. 2026. Tax Function Transformation: Scenario planning for the new normal. PwC Global, London, UK.

Schoueri, L.E. 2024. Direito Tributário. 13ed. Saraiva, São Paulo, SP, Brasil.

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

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