IBS and CBS in the HOF Clinic: What the Reform Changes

The consumption tax reform is the biggest adjustment to Brazil's tax system in decades, and the owner of an orofacial harmonization (HOF) clinic hears about it without knowing what actually changes day to day. The short answer: in 2026 little changes in your pocket and quite a lot in your invoicing routine; in the following years, the subject starts to weigh on pricing, on the choice of regime and on cash flow.

This guide explains the basics, the schedule and what to ask the accountant. It is not tax advice: the rules are still being regulated and amended, and the correct classification of each activity needs professional analysis.

What are IBS and CBS?

They are two new taxes on the consumption of goods and services:

• CBS (Contribution on Goods and Services): federal. Replaces PIS and Cofins.
• IBS (Tax on Goods and Services): for states and municipalities, run by a Management Committee. Replaces ICMS and ISS.

The legal basis is Constitutional Amendment 132/2023 and Complementary Law 214/2025, with later changes by Complementary Law 227/2026. The new system follows the logic of a value-added tax: each step in the chain pays on its own value and can use credit for what it paid earlier, under specific rules.

For a service clinic, what matters is this: the municipal ISS, which today applies to providing the service, will gradually be replaced by IBS, and PIS and Cofins by CBS.

What is the transition schedule?

The table below summarizes what the Receita Federal (Brazil's federal tax authority) reports on its reform page. Confirm the dates in the current text, because the legislation has already been adjusted.

Official sources (in Portuguese): Understanding the Consumption Tax Reform (Receita Federal) and IBS Management Committee.

What changes on the clinic's invoice?

In 2026, anyone who already issues tax documents must follow the rules for showing IBS and CBS. According to the Management Committee, in this phase the amounts are informational, are not part of the transaction total, and on the electronic service invoice filling them in is initially optional. There is also no administrative penalty for good-faith errors during an adaptation period set by the rules.

For the Simples Nacional, the notice states there is no change in 2026, and that those enrolled start showing IBS and CBS from 2027.

In practice, what the clinic should do now:

1. Ask the accountant whether your invoicing system is already ready for the new fields.
2. Check your municipality: the service invoice depends on municipal systems and the national standard, and the schedule varies.
3. Keep your billing history by service, because it will be the basis for simulations.

Do health services pay less?

Complementary Law 214/2025 (art. 130) provides a 60% reduction in IBS and CBS rates on the health services listed in its Annex III, identified by the Brazilian Services Nomenclature (NBS) classifications. The list is limited, and the reduction applies to what is on it.

The point that worries those who do HOF is whether the clinic's procedure falls within that list. That can't be answered in one sentence: it depends on the nature of the service, on the classification shown on the invoice and on how the legal text is read. Two precautions:

• don't assume the reduction applies, or that it doesn't;
• ask the accountant for a written analysis of how each of the clinic's services is classified (consultation, procedures, product sales).

The text of the law is on the Planalto website, and the accountant should check the updated version with later amendments.

What about a clinic under the Simples Nacional?

The Simples continues to exist. What changes is how IBS and CBS relate to it, and this is where the clinic should ask the accountant for a simulation. Points to ask:

• How will payment work within the Simples from 2027?
• Is it possible to opt to pay IBS and CBS outside the Simples, and when does that make sense?
• Does the credit for those who buy from my clinic change depending on my regime?

A point of logic: the credit from the new taxes only matters to the buyer who is a taxpayer. If almost all your customers are individual patients, who can't use credit, that aspect weighs less for your clinic than for a company selling to other companies. Even so, credit on your purchases (supplies, rent, equipment) may matter under the regular regime. The accountant's simulation should take this into account.

For a broader view of taxes in pricing, see the page on pricing per ml, where taxes and fees go into the formula's divisor.

How can the reform affect pricing?

The price of a service must cover cost, tax, fees and margin. If the tax burden on revenue changes, the math changes. The reasoning follows the formula:

Price = direct cost ÷ (1 − taxes − fees − margin)

Hypothetical example: direct cost of R$ 445.00 per ml, card fees of 4% and a desired margin of 30%. With taxes of 6% on revenue, the minimum price is R$ 445.00 ÷ 0.60 = R$ 741.67. If the burden rose to 8%, the minimum price would be R$ 445.00 ÷ 0.58 = R$ 767.24, about 3.4% higher. The percentages are fictional and don't represent the burden of any real clinic.

What the example shows is the method, not the answer. Only raise prices after the accountant estimates your clinic's burden under the new taxes. Use the installments and fees and break-even point calculators to test cost and minimum revenue scenarios.

What to do in 2026 and 2027?

Checklist for talking to your accountant

• Is my invoicing system ready for the IBS and CBS fields?
• What is my regime today and what is the expected impact from 2027?
• Do my services fall under Annex III of LC 214/2025? Can you give me that in writing?
• Is it worth staying in the Simples, or is there a better scenario for my revenue?
• Which of my expenses can generate credit under the regular regime?
• How does withholding work when I treat patients through an insurance plan or a partner company?
• When should I review the price of procedures?

The reform is a long process, with dates through 2033. The clinic that gets organized early, with billing by service, correct invoices and a frank conversation with the accountant, reaches the changes with data in hand and fewer surprises in pricing.