Brazil Makes Important Changes to the Electronic Invoicing System
Brazil’s tax authority, the State Secretary of Finance (SEFAZ), has announced important changes to the country’s electronic invoicing system. Developments include the introduction of new types of electronic tax documents, adjustments to delivery requirements, and new functionalities in the SEFAZ platform.
Below the changes are explained in more detail.
New Types of e-Documents in Brazil
The declaration of 2 types of e-delivery notes will begin in August.
Canhotos are delivery notes that were generated and signed on paper as part of the DANFE or DACTE system before this change. Beginning in August, canhotos for both invoices (NF-e, Nota Fiscal Eletrônica) and shipping notes (CT-e Conhecimento de Trasporte Eletrônico) can be issued electronically.
Each of these messages corresponds to another commercial transaction. The canhoto is an electronic message with its own XML format that needs to be signed electronically and sent to the SEFAZ for approval.
- CT-e electronic canhoto: Delivery note related to a CT-e, issued by the logistics provider.
Message issued by the logistics provider that certifies the delivery of merchandise.
- NF-e electronic canhoto: Delivery note related to an NF-e, issued by companies with their own logistics operations
Message issued by companies with their own logistics operations that certifies the delivery of merchandise.
The legislation also allows for the cancellation of electronic canhotos. For the moment, their issuance is optional and the printed version in the DANFE and DACTE system is still in use.
The implementation of electronic delivery slips for valuables (GTV-e) will begin in September.
The GTV-e, used as proof of transport of valuable items, is issued and stored electronically. Its legal validity depends on the electronic signature of the issuer and the tax authority’s validation.
Characteristics of the GTV-e:
- Must contain information about the goods carried: number of packages/bags, type of valuable (cash, checks, etc.) and the numeric value of each
- Must be identified by an access key containing the following: a code number generated by the issuer, their CNJP, and the GTV-e series and number
- Standard XML format
- Numbered sequentially from 1 to 999,999,999, by establishment and by series
- Must be signed electronically by the issuer
This new e-document will cover the entire shipment, substituting the current CT-e OS document. It can be used in all Brazilian states (Unidades Federativas). For now, use of the GTV-e is voluntary. Authorities are considering requiring its implementation starting in September 2022.
The introduction of the electronic energy fiscal note (NF3-e) will substitute the current electricity invoicing system. Until now, electric energy providers issued a monthly magnetic file containing all the invoices from that month. Making this document digital will assist both taxpayers, by simplifying their declaration process, as well as tax authorities, which can track their issuance in real time. The model 66 NF3-e will replace the model 6 invoice.
The NF3-e, which documents operations related to electric energy, is created and signed electronically. Its legal validity depends on the use of electronic signatures and the local tax administration’s prior validation of the document.
Use of this document will be mandatory beginning on 1 March 2021 for all electricity distributors and cooperatives. Before that date, companies whose local tax authority is ready to provide the validation service for these documents can voluntarily issue the NF3-e.
Characteristics of the NF3-e:
- Must be signed electronically by the issuer
- Standard XML format
- Numbered sequentially from 1 to 999,999,999, by establishment and series. Numbers will restart when the limit is met
- Must contain a numeric code generated by the issuer containing the following: the NF3-e identification key, the issuer’s CNJP, NF3-e and issuer’s series number
Like many other DF-e documents, the SEFAZ contemplates use of a graphic representation of the NF3-e, the DANF3E, a visual representation of some NF3-e fields to be sent monthly to the consumer.
Characteristics of the DANF3E:
- Must guarantee the legibility of all information specified in the technical guidelines
- Must contain a bidimensional code with a digital authentication mechanism that allows for the identification of the NF3-e issuer
- Must contain a printed authorization protocol number which proves SEFAZ authorization
Communications Fiscal Note - NFCom
Another electronic invoice being introduced by the SEFAZ is the Communications Fiscal Note. All Brazilian communications companies will need to issue this document. This project is still under development by the tax authority.
The NFCom will replace the model 21 communications fiscal notes and model 22 telecommunications fiscal notes, both regulated by the concerted ICMS 115/03 which was published by the CONFAZ.
New Functionalities of the SEFAZ e-Invoicing Platform
The SEFAZ will use notifications to advise users of errors in electronic invoices. From now on, the SEFAZ will not reject e-invoices (NF-e, NFC-e) when an error is detected, but will send an error notification to both the issuer and the recipient.
Invoice issuers are required to make the corrections within a limited time.
One objective of these notifications is to encourage better practices in e-invoicing. For that reason, the failure to rectify errors will not result in sanctions at this time.
Centralized Taxpayer Registry - CCC
SEFAZ tax authorities consult the taxpayer registry to validate electronic invoices. Currently, each SEFAZ has its own registry called a National Taxpayer Registry (CNE). To facilitate interoperability between the Brazilian states, the National Council of Finance Policy (CONFAZ) proposed the creation of a Centralized Taxpayer Registry (CCC) which will contain data from all CNEs. Having taxpayer information centralized in one registry will allow any SEFAZ to validate interstate operations. The authorities are also evaluating the possibility of having the CCC replace the SINTEGRA registry.
Implementation of New Requirements for Electronic Invoice Issuance
Electronic Invoicing in Brazil
Brazil is a global leader in the use of electronic invoices and other e-tax documents. Electronic invoicing is part of the country’s innovative and complex tax system in which the exchange of electronic data is extremely important. The tax administration is 100% digital and is managed by various state, federal and local entities.
Legislative decisions are made by the National Council of Finance Policy (CONFAZ) and implemented by the State Secretary of Finance (SEFAZ). The SEFAZ has various entities at the federal state level, each one being the official tax authority of that region.
Electronic invoicing in Brazil is obligatory and follows a clearance model, requiring prior validation by the SEFAZ before shipment of goods.
The EDICOM electronic invoicing solution automatically generates electronic tax documents in line with the technical and legal requirements and declares them to the SEFAZ. It also electronically signs the DF-e on behalf of the issuer. The EDICOM solution can be integrated with any management system (SAP, DYNAMICS, JD EDWARDS, ORACLE, etc.), allowing users to generate invoices in line with the complex Brazilian tax law.