Tax Reform: why your company could stop issuing invoices if you don't do your homework now

The Brazilian tax reform is no longer a distant promise: it is already in force, coexisting with the old system while changing rules practically every month. It was on this shifting ground that Ari Pellicioli and Eden Paz, partners at ConsulPaz, welcomed Ângela Daltoé in the most recent interview for Conteúdo Compartilhado magazine.

Corporate manager of costs and tax accounting at Tramontina, with 42 years at the company completed in September, Ângela leads the company's tax reform project and balances this role with university teaching. In this conversation, she reconstructs a trajectory that began at age 16 in retail, at the Tramontina store — when she didn't even know how to distinguish the products she sold — until reaching the table where she now dialogues directly with the company's main shareholders.

In our interview, Ângela shares the concrete impacts of the reform: from taxation migrating from origin to destination, the more than one hundred new fields in the invoice XML, to the real risk of stalling a company's operation due to a simple registration error. "If you don't have everything one hundred percent right, the invoice will not be issued," she summarizes. 

The discipline that comes from "I don't know, but I'll learn" 

Ângela started at Tramontina by chance at age 16 — the opening was for her sister, who preferred to work at another store. She ended up in the company's retail division, without even knowing the names of the products she sold. "I knew absolutely nothing, not even what a serving dish or a piece of cutlery was," she recalls, laughing. What set her apart, according to her, was the willingness to admit what she didn't know: "I told him the truth: I don't know it, I don't know how, but I'm here willing to learn. And that's what he liked about me, because I was sincere." From there, she went through the collections area, manual filing of reports in the IT area, and arrived at accounting — an area that was not her original dream. Ângela wanted to be a musician; she has been singing and playing guitar since she was young. It was her father, also a musician, who guided her: "Choose a profession where you can support yourself. Music doesn't support you." She chose Accounting Sciences. 

The turning point, she says, was a period helping in the company's dead files. Instead of just filing documents, she decided to use them to learn accounting in practice, account by account. "I took all the documents one by one and started to learn accounting. That's where I dived in and understood the accounting world," she says. "My world opened up." Her education never stopped: Bachelor's in Accounting Sciences from Unisinos, postgraduate in People Management, MBA in Controlling, MBA in Business Management from Fundação Dom Cabral, MBA in Tax Reform, and currently a Master's in Finance, Governance, and Financial Management. Ângela is also a postgraduate professor at the University of Caxias do Sul in the areas of financial management, strategic costs, and strategic tax management. 

“I don't know, but I'll learn. I think that's the secret to everything.” 

As Ari highlighted while conducting the interview, this is an unusual trajectory for new generations, who might not even know what a "dead file" with A-Z folders and hand-filled forms for IT to process is. Ângela credits much of her logical reasoning to music — "anyone who plays guitar or lives in the music world learns logical reasoning, and I didn't have it, so I had to learn" — and to the decision to build multidisciplinary teams throughout her career, which today brings together accountants, lawyers, a PMO, and even an engineer. "I need to understand costs, I know costs, but the engineer knows the factory," she explains. "That's what brings richness into the company." 

From origin to destination: the tremor the reform causes in systems 

Returning to Ari's observation about the reform schedule — in effect since January, with gradual implementation until 2033 — Ângela was direct about the current stage: "For now, nothing is simplified." For her, this is expected in a transformation of this size, but the volume of technical work surprised even experienced professionals. "One of the great challenges today is being able, through technical notes, to bring all the changes to reality. I went to several training sessions where people didn't even know where to download the technical note," she reports. 

The core of the change, according to her, lies in the logic of taxation: instead of collecting tax based on the origin of the goods, the new model taxes at the destination — which reshapes logistics decisions and even the location of factories and distribution centers. "I'm not going to look at whether the goods are leaving Rio Grande do Sul. I'm going to look ahead, when the IBS kicks in, at the municipality. Everything changes, and the rates change," she describes. In the technical field, the impact is equally large: there are more than one hundred new fields to configure in the electronic invoice XML, involving IT, tax, and business in equal measure. "Tax and technology have to be stuck together, they cannot drift apart," summarizes Ângela, describing the need for constant alignment between the areas. 

Expanding on this idea, she draws attention to companies that, in addition to the reform, are in the process of changing systems (for example, migrating to SAP): in these cases, it is necessary to keep two environments running in parallel — the legacy and the new — until the transition is complete, which doubles the effort of the technical teams. "When we migrate systems, the pain is even greater," she states. 

The credit that only arrives when the supplier pays 

One of the points that drew the most attention in the interview was the change in the appropriation of tax credits. In the current reform model, the company does not credit the tax at the time it receives the invoice, but only when the supplier actually pays the tax. "And if the supplier doesn't pay, I have to pay. I have a very large cash flow effect," warns Ângela. This forces companies to review the entire supplier chain — analyzing each one's tax regime (Actual Profit, Presumed Profit, or Simples Nacional) — because the impact varies enormously depending on the classification. In the service sector, for example, she cites increases that can reach more than 100% in the tax burden for Presumed Profit companies, although the effect is smaller for those under Actual Profit. 

According to the executive, the regulation still under construction worsens legal uncertainty: "We are still in the regulation phase, we will still have more regulations ahead." Added to this are divergent interpretations between companies and system providers — she cites six months of work just to align the treatment of debit and credit notes with Tramontina's ERP provider — and the scarcity of qualified professionals: "Most large corporations are working with the same number of employees, and we have to handle the day-to-day and the tax reform." 

“If you don't have all the tax reform fields one hundred percent right, the invoice will not be issued and it will stall the company's operation.” 

Ângela also warns about so-called data cleansing — correct address registration, tax classification (NCM), and tax framing. A simple error could mean loss of credits or, worse, an automatic fine, since the new invoice issuance model has instant traceability with tax authorities. "If I issue a tax document, it automatically has traceability. The government can already fine me. A tax inspector doesn't need to go there anymore," she describes. For her, this is currently the greatest technical challenge she has ever faced in her career — even greater than the SAP implementation, which she considered, until then, the most complex project of her trajectory. 

Big players are racing ahead; small and medium ones are still sleeping 

Asked by Eden about the degree of preparedness of Brazilian companies, Ângela paints an unequal scenario. Large companies — she mentions participating in committees with major retailers, alongside PwC, and contacts with companies like Marco Polo and Randon — have already been preparing with dedicated teams and specialized consultancies. The situation changes for small and medium-sized companies, historically dependent on outsourced accounting firms, which according to her took a long time to mobilize and address the issue with their clients.  

For Ângela, accounting firms will also feel the impact of the reform — including needing to invest in technology and specialized professionals, a movement that has already led colleagues to consider selling their portfolios. "What I think took a long time was for people to wake up, to believe that this was going to happen," she evaluates, even predicting a reduction in the number of accounting firms in the coming years. In her view, the reform is already a fait accompli from a legal point of view — it was approved via constitutional amendment — and the political debate may alter rates or deadlines, but not the general direction of the transition. 

What to do now 

Given this scenario, Ângela advocates for an objective roadmap for leaders who haven't yet put the topic on their radar: set up multidisciplinary committees (don't leave the responsibility only to the tax department), run diagnostics and impact simulations per company, review contracts with suppliers and clients to include tax payment clauses, and involve senior leadership from the start. "I have meetings directly with the CFO, with the CEO, so they understand," she says. At Tramontina, she leads three-day internal training sessions aimed at all of Brazil, bringing together tax, accounting, finance, procurement, commercial, and IT — areas that, according to her, need to speak the same language in the face of the reform. 

Quick Glossary 

• IBS: Tax on Goods and Services, a tax under state and municipal jurisdiction created by the tax reform, which will replace ICMS and ISS. 

• CBS: Contribution on Goods and Services, a federal tax from the reform that will replace PIS and Cofins.

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• Invoice XML: Structured electronic file that accompanies each invoice and concentrates the tax data transmitted to the government. 

• NCM: Mercosur Common Nomenclature: code that classifies each product for tax purposes and defines its taxation. 

• IRP: System for issuing and managing electronic tax documents used by companies (e.g., market ERPs). 

• Actual Profit / Presumed Profit / Simples Nacional: Federal tax calculation regimes for companies, with distinct rules and impacts in the face of the reform. 

• Split payment / taxation at destination: Reform logic where the tax is collected considering the place of consumption of the good or service, no longer the place of origin. 

Faith, protagonism, and the turning point of the accounting profession 

Closing the conversation, Ângela summarized the spirit that, according to her, should guide companies: keeping the operation standing, with compliance and governance, avoiding automatic fines that the new tax traceability makes practically inevitable for those who do not prepare. "If it works out, it was everyone. If it goes wrong, it was the accountant," she joked, arguing that responsibility for the reform cannot fall only on the tax area.

As a final message to readers, she highlighted faith as part of her study routine and reinforced the moment of protagonism that the accounting category is experiencing: "More and more we are being seen as strategic within organizations. We don't just have challenges, we have opportunities." 

About Ângela Daltoé

Graduated in Accounting Sciences, with an MBA in Tax Reform and a Master's in progress in Finance, Governance, and Financial Management, Ângela Daltoé continues to lead Tramontina's tax reform project and teach at the University of Caxias do Sul — splitting her time between ensuring the company's operation doesn't stop and training the next generation of professionals who will deal with the new Brazilian tax system.