Electronic invoicing guide
Brazil

Reporting

This country does not require reporting.

Processes

The taxpayer must declare the NF-e and CT-e to the tax administration before sending the goods. The administration will issue an authorisation code that must be printed on the PDF of each invoice. On the other hand, the NFS-e must be declared to each “prefeitura” or municipality from where the service is invoiced.

However, Brazil has a complex electronic invoicing model for customs clearance, which requires the use of a different system depending on the category of the product: the electronic invoicing system to be used by suppliers depends on whether they invoice goods, services, etc.

The existence of different e-invoicing systems is one of the factors that make Brazil’s e-invoicing model complex. Adding to this complexity is the fact that regulations tend to be regional (state and even municipal).

For example, NF-e invoices for physical goods transactions follow the same framework throughout the country, regardless of their origin or destination of supply.

However, NFS-e bills involving services are taxed at the municipal level, and NFS-e requirements vary from municipality to municipality.

To reduce the complexity of the model, the Brazilian government is trying to implement a national standard for electronic invoices for services.

The country will have one national NFS-e system (SNNFS-e) instead of having different municipalities with different e-invoicing standards.

The harmonisation of NFS-e invoices creates a centralised portal for participants to register invoices. The system also introduces a national repository for all NPS-e invoices called the National Data Environment (NDE).

While all other service companies are legally obliged to comply with these requirements, the deadline for small taxpayers and companies without legal personality has been postponed from 3 April to 1 September 2023.

The sending of compliant e-invoices in Brazil differs depending on whether the supplier is a supplier of goods or services.

Sending NF-e invoices

To send compliant NF-e invoices for the supply of physical goods, the steps are as follows:

• Request a digital signature from your certified regional issuer: When you request a digital signature you will be provided with an invoice generation key. 
• Generates an invoice in XML format: It contains the tax information of the transaction. The invoice must be signed with your unique digital signature. 
• Send the invoice to your regional SEFAZ (Secretaria da Fazenda Estadual) via the web service: SEFAZ clears and authorises it as NF-e. You will receive a unique authorisation code that you must include on the NF-e invoice and in your ERP. You can then dispatch the goods.
• The NF-e is also transmitted to the Receita Federal do Brasil (RFB): The RFB operates the national repository of all electronic invoices issued in Brazil – Ambiente Nacional.
• Shipment of goods with delivery note: When goods are shipped through Brazil, they must be accompanied by a delivery note called DANFE (Documento Auxiliar da Nota Fiscal Eletrônica). This delivery note contains the NF-e access code that allows the holder to confirm the existence of the NF-e invoice on the SEFAZ or RFB website.
• Send the invoice to the customer for validation: After delivering the goods, you must send the NF-e invoice.

Sending NFS-e invoices

To send compliant NFS-e invoices for the provision of services, the steps are as follows:

• Issue a provisional receipt for services: Issue a provisional receipt for services (Recibo provisório de serviços – RPS). You can prepare the RPS manually or via the web service.
• Send the RPS: Send the RPS (in batches) to the municipality’s secretariat for NFS-e processing. You will receive a receipt protocol number as proof of sending a batch of RPS.
• Obtain your authorised NFS-e invoice: The Secretariat will place your RPS batch in a processing queue and service it accordingly. To validate the RPS, the Secretariat will check that the invoice is genuine and that the supplier has complied with tax regulations. After processing, you will get your authorised NFS-e invoice. If your RPS batch contains errors, the system will return a list of the errors found. You can then correct them and resubmit them for authorisation.
• Present the NFS-e: The NFS-e must be submitted to the municipality (prefeitura) from which the service is billed.
• Send to customer: Sends the NFS-e invoice to the customer for validation and approval.

Electronic invoicing model

• Brazil applies a pre-settlement e-invoicing system, which means that the supplier must submit the invoice to the tax authority for settlement before it can be issued to the customer.
• It is mandatory for all suppliers in Brazil to send electronic invoices through the system. It is also mandatory for all buyers to receive cleared electronic invoices. 
• So, whether your company issues an invoice to another company or to a final consumer, you must use the electronic system.
• Brazil requires all electronic invoices to be digitally signed before they are submitted to the relevant tax authority for authorisation.
• The electronic signature, which must be in XMLDsig format, can be signed using a digital certificate obtained from a certification authority certified by Infraestructura de Claves de Publicas (ICP Brazil).
• The electronic signature guarantees the integrity of the data and the authority of the issuer.