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Tributum

Simples vs. VAT: inside the DAS or the regular regime?

A simulation for Simples Nacional companies deciding whether to pay IBS and CBS inside the DAS or under the regular regime, taking into account the credit passed to customers.

The tax reform did not end Simples Nacional, but it created a choice the regime never had: a company can stay in Simples and still pay IBS and CBS (the new consumption taxes) outside the single payment slip (the DAS), under the rules of the standard regime. A company that chooses nothing stays with everything inside the DAS. The two routes cost different amounts and, above all, deliver a different credit to the customer who buys from you. Deciding well requires a calculation made with the company's own numbers.

Open deadlines

  • Cancellation of the option from November 3 to December 20, 2026

Who it is for

For Simples Nacional companies (micro and small businesses) that sell, wholly or partly, to other companies: industry, wholesale, distribution and business-to-business service providers. The MEI (individual microentrepreneur) follows the rules of its own regime.

A simulation is usually worthwhile if your company:

  • sells a significant share to customers under the Presumed Profit (Lucro Presumido) or Actual Profit (Lucro Real) regimes;
  • has heard from a buyer that the IBS and CBS credit will factor into supplier selection;
  • buys significant volumes of goods and inputs from regular-regime suppliers;
  • has revenue approaching the Simples sublimit;
  • wants to decide with numbers, not just a hunch, before the election windows.

For companies that sell mainly to final consumers, such as neighborhood shops, gyms, clinics and bakeries, the default route tends to be enough. The simulation is there to confirm this with your own data, not by assumption.

Inside or outside the DAS: the two routes

From 2027, PIS and Cofins give way to the CBS, and the IBS gradually replaces ICMS and ISS. For Simples companies, these two new taxes have two possible paths.

  • Inside the DAS (the default)The company keeps the single payment slip, at the rate of its annex. This is the route for anyone who makes no election. It is also called pure or conventional Simples.
  • Outside the DAS (by election)The company stays in Simples for the other taxes, such as IRPJ, CSLL and the employer social security contribution, but calculates IBS and CBS under the regular regime, with debits and credits, paid separately. The market calls this model hybrid Simples. The DAS is then calculated without the portion corresponding to these two taxes.

You do not need to leave Simples to choose the second route. Switching between the two routes can only be done in the designated windows.

Credit is the heart of the decision

Imagine a Simples manufacturer selling to a retail chain under the Actual Profit regime. The chain wants to know how much IBS and CBS it can offset against what it pays itself. Inside the DAS, the buyer can only use credit on the portion of IBS and CBS set out in the Simples annexes for the supplier's revenue bracket, as shown on the tax document. Because that portion is small within the Simples rate, the credit is small. Outside the DAS, the buyer takes the full credit, on the same terms as with a regular-regime supplier.

For companies selling to final consumers, this difference does not matter, because consumers do not use credit. For those selling to other companies, it can weigh in the negotiation: a competitor that delivers full credit may be cheaper for the buyer, even at the same invoice price.

Credit also works in the other direction. On the route outside the DAS, the company starts offsetting against IBS and CBS what it paid on its own purchases of goods, inputs, electricity, rent and freight, provided there is a correct tax document issued to its CNPJ (company tax ID). Payroll does not generate this credit, so labor-intensive companies benefit less. Between two Simples companies, credit hardly circulates on either route.

The calendar that matters

September 1 to October 30, 2026Window to elect the regular IBS and CBS regime, effective from January 1, 2027, extended by CGSN Resolution 194/2026. Companies that do not elect stay with both taxes inside the DAS, with nothing further to do.
November 3 to December 20, 2026Window to cancel the election.
By December 15, 2026Deadline for the Senate to set the CBS reference rate for 2027.
January 1, 2027The CBS is charged in full. An election made by October 30, 2026 takes effect from this date.

The cancellation window ends after the Senate's deadline to set the CBS rate, which allows the decision to be checked against the official figure. For that reason, the simulation is run on assumptions and redone when the rate is set. Note two different choices: the election to join or return to Simples Nacional in 2027 had a deadline of October 15, 2026; the choice of how to pay IBS and CBS, covered here, is a separate one, with a deadline of October 30, 2026.

2027 is, above all, a decision about the CBS

In 2027 and 2028 the IBS is charged at 0.1% in total, so almost all the weight of the decision rests on the CBS. The IBS gains weight from 2029. A simulation that applies the full IBS rate already in 2027 overstates the benefit of the first year. That is why the calculation has to be read across the entire transition, not just the first year. In 2026, Simples companies do not pay IBS and CBS during the test phase.

What we deliver

You receive a comparative calculation of the two scenarios and a technical recommendation to decide with.

  • Audited tax base before the simulationItem classification, revenue segregation by annex and identification of monophasic goods and tax substitution. Simulating on a wrong base only produces a wrong conclusion that looks precise.
  • Simulation of both scenarios from the company's own filesPurchase and sales invoices and Simples returns, not market averages.
  • Customer portfolio analysisHow much of your revenue goes to regular-regime companies, to final consumers or to other Simples companies, and what that means in terms of credit.
  • Technical recommendationWhich route tends to make more sense for your company, with the assumptions and caveats explained in clear language.
  • Election and cancellation calendarThe dates that apply to your case, so that no window is missed.

How it works

  1. 01

    Conversation and portfolio map. We understand who the company sells to and who it buys from. We agree on scope, timeline and price before we start.

  2. 02

    Tax base audit. We check classification, segregation by annex and the treatment of monophasic goods and tax substitution, so the simulation starts from reliable numbers.

  3. 03

    Simulation of the two scenarios. We calculate the cost and the credit passed to the customer on each route, across the transition, treating the CBS rate as an assumption until it is set.

  4. 04

    Recommendation and calendar. We present the conclusion in plain language and redo the calculation when the official rate is published, within the cancellation window.

The recommendation depends on the company's data and on the rules in force, which are still being regulated; it is therefore guidance for deciding, not a promise of results. The CBS reference rate for 2027 is still to be set by the Senate. Basis: Complementary Law 214/2025 (articles 41, 344, 348 and 349), Complementary Law 123/2006 and CGSN Resolution 194/2026. Updated on October 29, 2026. Where a matter requires legal representation, it is hired directly by the client from professionals of their choice.

Frequently asked questions

Do I need to leave Simples Nacional to pay IBS and CBS outside the DAS?
No. The company stays in Simples for the other taxes. Only IBS and CBS leave the single payment slip.
What if I make no election?
Nothing changes in the process: IBS and CBS stay inside the DAS. You do not need to make a new election to stay on the default route.
Can I change my mind after electing?
Yes. From November 3 to December 20, 2026, you can cancel the election. After cancellation, IBS and CBS return to the DAS.
I missed the October 30 deadline. What now?
A company that does not elect by October 30 stays with IBS and CBS inside the DAS, with nothing further to do. Any new election windows depend on regulation by the Simples Nacional Steering Committee (Comitê Gestor do Simples Nacional).
Is paying outside the DAS always better?
No. It tends to make sense for those who sell largely to regular-regime companies and have significant purchases that carry credit. For those who sell to final consumers, it usually brings more control and paperwork without a competitive advantage. Only a simulation with the company's own data can answer.
What will the CBS rate be in 2027?
It is not yet defined. The Senate must set it by resolution, by December 15, 2026, based on calculations from the Federal Court of Accounts (Tribunal de Contas da União). That is why we work with assumptions and redo the calculation when the official figure is published.
What about the MEI?
The MEI follows the rules of its own regime. The effect shows up in the commercial relationship, because buyers who calculate credit may take it into account when choosing suppliers.
Will the company have more obligations?
On the route outside the DAS, yes: it must track purchase credits, validate incoming documents and follow a separate calculation. Credit control remains with the company and its accounting team.
Is there anything to watch regarding credit refunds?
Yes. The law bars leaving the regular IBS and CBS regime for a company that received a refund of credits on these taxes in the current or the previous year (article 41, paragraph 5, of Complementary Law 214/2025). Companies that tend to build up a credit balance should therefore evaluate the decision over a longer horizon.
Do you guarantee savings?
No. The simulation shows how each route behaves with your company's data, with assumptions and limits explained. The price of the work is agreed before we start.

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