Towards a new theory of the tax obligation for IBS and CBS
Charles W. McNaughton and Cristiane Pires McNaughtonConjur · Apr 23, 2026
Originally published on Conjur on Apr 23, 2026. Atualidades Tributárias column, ConjurRead on Conjur
In 1 minute
- The National Tax Code model, in which the taxable event creates the obligation and the assessment constitutes the credit, needs to be broadened for IBS and CBS.
- IBS has joint creditors (the destination state and municipality), and “atomic” obligations, one per transaction, coexist with a “molecular” one, the period’s balance.
- This affects practical questions such as when limitation periods start and whether the Steering Committee can be a party to proceedings.
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