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Tax Reform to Reshape Brazil’s Port and Logistics Sector, ATP Study Finds
Feb, 19, 2025 Posted by Gabriel MalheirosWeek 202508
The Tax Reform enacted earlier this year in Brazil is the focus of an unprecedented study by the Association of Private Port Terminals (ATP) in partnership with Cascione Advogados. The study compiles key questions and answers (Q&A) about the reform, which is set to take effect in 2026, with a full transition period extending until 2032. The changes will have far-reaching implications for Brazil’s port and cargo logistics sector, which plays a crucial role in both foreign trade and domestic coastal shipping (cabotage).
Released on Monday (Feb 17), the document outlines the broad tax base that will apply to the port industry under the new Goods and Services Tax (IBS) and Contribution on Goods and Services (CBS)—a dual VAT system. It also includes a glossary explaining key technical terms. The IBS and CBS will impact lease agreements, land-use concessions, and the leasing or rental of containers. The new tax framework will also apply to a wide range of port services, including berthing, cargo handling, storage, and area segregation (such as yards and warehouses).
According to ATP, the combined IBS and CBS rates are expected to range between 26.5% and 28%. However, reduced tax rates will apply to certain goods, services, and industries. The effective tax burden may vary depending on whether a business operates at the beginning, middle, or end of the supply chain.
“With the dual VAT system, Brazil is aligning itself with global supply chains, moving away from tax isolation. While this simplification could help attract new investment, it is crucial to monitor the overall tax burden to avoid overburdening the port sector,” said Gabriela Costa, ATP’s Executive Director.
Impacts on Port and Cargo Logistics
Beyond enhanced transparency and simplification, ATP sees another major benefit in the reform: the clear definition of tax jurisdiction. The IBS and CBS will be levied based on where port services are performed and where goods are delivered or made available in freight transport. This ensures that port municipalities receive essential tax revenues, allowing for infrastructure and urban development investments, both critical to the efficient operation of Brazil’s ports.
Currently, port and logistics services are subject to a 5% ISS (Municipal Services Tax), as well as PIS and Cofins contributions totaling 9.25%. Under the reform, the sector is expected to be taxed at 17.7% for IBS and 8.8% for CBS, pushing the total tax burden for port operations up by approximately 12 percentage points to 26.5%, according to ATP’s technical study released late last year.
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