Imports run through SAP tax: the DUIMP changes when and how
Imports and exports cross SAP in several modules, and tax is where cost, tax and bookkeeping meet. The Single Import Declaration (Duimp), the tax reform and customs regimes change what the tax team must receive, book and prove.
Where to start? It depends on your role
Each role has its own starting point.
01Tax and accounting
Import taxes, customs value, exchange rate, reconciliation and what the inbound invoice must carry.
Go to the section02Foreign trade and logistics
Duimp and its schedule, special regimes, exports, and who tells the tax team when the goods are delivered.
Go to the section03IT and integrator
What the enterprise resource planning (ERP) system must keep from the declaration, attributes by Mercosur Common Nomenclature (NCM), integration with the Portal Único and the test cases.
Go to the section04Executives and project
What the reform changes, what is the client's decision and how to prove the system's behavior.
Go to the sectionWhat changes and what tax must reconcile
According to Joint Act RFB/CGIBS 4/2026, the Duimp is the tax document for the Contribution on Goods and Services (CBS) and the Tax on Goods and Services (IBS) for taxable events from 01/01/2027. Before and after that date, the SAP tax team must reconcile declaration, invoice, cost and tax assessment.
What it says
The Duimp is gradually replacing the Import Declaration (DI), operation type by operation type (Portal Único schedule). Under the reform, CBS and IBS on imports arise at release, are paid by the delivery of the goods, and are based on the sum of the entry taxes and fees.
What SAP must show
Declaration, inbound invoice, inventory cost and tax assessment telling the same story, component by component. For exports: declaration (DU-E), endorsement, invoice and proof within the deadline.
What belongs to the client
Customs regime, authorizations, tax position and acceptance of each difference. DFSpro designs and configures the tax side and proves the system's behavior.
From cargo to SAP tax
Seven steps link the cargo to tax. The first four belong to foreign trade and the Portal Único, and the last three belong to SAP. The source for steps 1 to 4 is Portaria Coana 165/2024.
Cargo and manifest
Sea or air cargo is manifested in the Cargo and Transit Control module (CCT-Import). The Duimp can be registered before arrival (Portaria Coana 165/2024, arts. 3 and 4).
Registration and payment
Registration starts clearance and takes effect only when payment of federal taxes and of the Integrated Foreign Trade System (Siscomex) fee is confirmed (art. 5).
Channel and inspection
Green, yellow, red or gray channel. The broadest one between customs and the consenting agencies prevails (art. 7).
Release and delivery
The warehouse operator reports delivery in the CCT. The state value-added tax (ICMS) is settled through the Centralized Foreign Trade Payment (PCCE) so that delivery can be authorized (arts. 11 and 12).
Inbound invoice
The Electronic Invoice (NF-e) is required together with the Duimp and issued at delivery or release, whichever comes first (Decree 12.955/2026, arts. 77 and 113).
Entry in SAP
Cost, credit, inventory and accounts receive the values from the declaration and the invoice. This is where most differences are born.
Assessment and filings
The values go on to tax assessment and ancillary filings, and they must match what the declaration reported.
Assessment after entry is covered in tax assessment in SAP, and the inbound invoice flow is covered in automatic document entry.
Duimp: what the rule says and what the schedule has already switched off
The Duimp is the declaration of the New Import Process. Portaria Coana 165/2024 defines how to register it and sets the schedule for mandatory use (Official Gazette of the Union). These are the points that change the tax team's work.
| Point | What Portaria Coana 165/2024 says | Art. |
|---|---|---|
| Who imports by Duimp | An individual or a legal entity authorized to operate in foreign trade in a modality other than limited. Import on behalf of a third party and import by order have their own conditions. | 2 |
| When to register | Before the cargo arrives at the final destination of the bill of lading. After arrival, only once the warehouse operator has received the cargo. | 3 |
| When it applies | Sea or air cargo manifested in the CCT-Import, with an administrative treatment with no consenting agency, with a License, Permit, Certificate or Other (LPCO) or with Consenting Agency Inspection. | 4 |
| Start of clearance | Registration marks the start of clearance and requires a regular registry status, linked cargo, no blocking irregularity and confirmed payment, including the Siscomex fee. | 5 |
| Payment | Federal taxes and anti-dumping, countervailing or safeguard duties are paid at registration, by electronic tax collection form (Darf) with automatic debit in the PCCE module. | 6 |
| ICMS | The importer meets the ICMS obligations in the PCCE so that delivery can be authorized. The state's automatic integration waives this step. | 11 |
| Amendment and cancellation | The importer amends in the Portal. After clearance, the importer pays the taxes assessed in the amendment. Cancellation requires a Tax Auditor. | 13 to 15 |
| Mandatory use | The single Annex sets the schedule by operation. A DI registered where the Duimp is mandatory is canceled by the tax authority. | 16 |
The DI switch-off schedule
The Portal Único schedule (version 28, of October 2, 2026) depends on validation by the private sector (switch-off schedule). Three situations deserve attention:
The license is not switched off
Siscomex switches off the DI, not the Import License (LI). If the LI is registered after the operation has been switched off, an attempt to register the DI gets a message asking for a Duimp.
Special warehouse and public administration
Nationalization from a special warehouse admitted by DI, and public administration bodies (Group 1) that pay through the Integrated Federal Financial Administration System (Siafi), follow the schedule of December 1, 2026.
Several consenting agencies
With more than one consenting agency, the DI is switched off only on the date when all agencies have switched off. The same applies to more than one tax regime in the operation.
The date for your operation
The switch-off day for each operation type is in the full Portal Único spreadsheet. Confirm it with your customs broker before setting the change window in the ERP.
In practice, the tax team needs to know, for each operation, whether it runs by DI or by Duimp, because payment at registration and amendment after clearance change the calendar of the values.
Siscomex, attributes and integration: what the ERP keeps
The Duimp carries much more structured data than the DI. According to the Portal Único, attributes by NCM, reported in the Product Catalog, in the Duimp and in the LPCO, replace the Customs Valuation and Statistical Nomenclatures (NVE), the highlights and the description fields of the forms (NPI attributes).
What the Portal Único defines
- The Portal Único accepts integration by REST API, in a machine-to-machine standard, only for companies and representatives authorized by the Federal Revenue Service (Integrate your system).
- There are training and production environments, with different attribute codes in each.
- Attributes by NCM, in XML and JSON, are exchanged every midnight. They were updated on 31/07/2026 (NPI attributes).
- The Single Export Declaration (DU-E) is registered by web service.
What is a project decision
- Whether the company integrates the ERP with the Portal Único or uses the customs broker as a bridge.
- Who maintains the Product Catalog and how it talks to the material master.
- In which SAP field each piece of declaration data is stored.
- Who receives the release and delivery notice.
What the ERP must keep from the declaration
Each item is a field or a table that tax should be able to find in the system without asking for a spreadsheet.
- Duimp or DI identifier and registration date.
- Inspection channel and release date.
- Date the warehouse operator delivered the goods, which tax needs to know.
- Customs value, exchange rate and each tax paid, by item.
- Entry customs regime and, where there is one, term and concession act.
- NCM and attributes reported in the declaration, next to the material's NCM.
- LPCO number and consenting agency, when the operation requires it.
- Import location reported in the declaration.
Import taxes, one by one
The rule, tax by tax. Benefits, reductions, capital-goods exemptions (ex-tarifários) and the choice between regimes are the client's decision, with its own specialist.
| Tax | Taxable event and timing | Tax base | Source |
|---|---|---|---|
| Import Duty | Entry of foreign goods into the customs territory. For calculation purposes, it occurs on the registration date of the DI for goods for consumption. | Customs value, when the rate is ad valorem. Rates from the Common External Tariff. | Customs Regulation (RA), arts. 72, 73, 75 and 90 |
| Tax on Industrialized Products (IPI) | Customs clearance of products of foreign origin. The taxpayer is the importer, and payment is at registration of the declaration. | Import duty base, plus the tax itself and the exchange charges paid or due. | RA, arts. 238, 239, 241 and 242 |
| Social Integration Program (PIS) and COFINS-Import | Entry of foreign goods into the national territory. For calculation purposes, on the registration date of the DI for goods for consumption. | Customs value (Law 12.865/2013 removed ICMS and the contributions themselves from the base). General rates in art. 8: 2.1% and 9.65%. | Law 10.865/2004, arts. 3, 4, 7 and 8 |
| ICMS | Customs clearance of goods imported from abroad. Delivery depends on settlement in the PCCE. | Value of the goods in the import documents, plus import duty, IPI, foreign exchange transaction tax and other taxes, fees, contributions and customs expenses. | Complementary Law (LC) 87/1996, arts. 12, IX and 13, V |
| Additional Freight for the Renewal of the Merchant Marine (AFRMM) | Actual start of unloading the vessel at a Brazilian port. | Freight, the remuneration for waterborne transport. Rates by type of navigation in art. 6. | Law 10.893/2004, arts. 4 to 6 |
| Siscomex fee | Due at registration of the declaration, per declaration and per addition. | Amounts set in art. 306, adjustable by act of the Minister of Finance. | RA, art. 306 |
ICMS rates and benefits
ICMS rates and benefits on imports vary by state: see state tax benefits. The current Siscomex fee amount is set by act of the Minister of Finance.
For SAP, there is only one question: does each line of the declaration have a destination in the invoice, in cost and in tax assessment? The answer is proved by reconciliation.
Customs value: items that add to the value and items that stay out
Customs value is the base for import duty and the starting point for CBS and IBS. It follows the Customs Valuation Agreement, which the Customs Regulation reproduces (Decree 6.759/2009, arts. 75 to 80).
Part of the customs value
- Transport cost to the bonded port or airport of unloading, or the bonded border point (art. 77, I).
- Loading, unloading and handling costs associated with transport to that place, excluding those incurred in the national territory and itemized apart from transport (art. 77, II).
- Insurance cost for these operations (art. 77, III).
Not part of it, if itemized apart from the price
- Construction, installation, assembly, maintenance or technical assistance carried out after import (art. 79, I).
- Transport and insurance incurred in the customs territory from those places onward (art. 79, II).
- Interest on purchase financing, if itemized, in writing and within the conditions of art. 80.
When the declaration covers goods of more than one NCM, transport is split by net weight and insurance by the value of the goods (art. 78 of the Customs Regulation). In cases of fraud or failure to meet the duty to support the declaration, the base may be set by assessment (art. 86).
Where each component comes from
Price of the goods
Born in purchasing and foreign trade. Tax asks for the commercial invoice and the declaration value.
International freight and insurance
Born in logistics. Tax asks for the bill of lading and the policy, with the split by addition.
Taxes and fees at registration
Born in foreign trade. Tax asks for the declaration statement, by tax and by item.
Storage and customs broker
Born in logistics and foreign trade. Tax asks for the service invoices and the rule for allocating them to cost.
Exchange rate
Born in treasury and accounting. Tax asks for the rate used in the declaration and the one used for the payment abroad.
Inbound NF-e, Duimp and export invoice
Two electronic tax documents now exist on import: the customs declaration, which the reform made a tax document, and the inbound invoice. The rule defines the sequence and the dates.
| Document | What the rule says | Source |
|---|---|---|
| Duimp | Electronic tax document for CBS and IBS. It becomes mandatory for taxable events from 01/01/2027. | Decree 12.955/2026, art. 113, XIV. Joint Act RFB/CGIBS 4/2026, art. 1, XIV |
| DIR, Remittance Import Declaration | Electronic tax document for imports by remittance, starting on 01/10/2026. | Decree 12.955/2026, art. 113, XV. Joint Act 4/2026, art. 1, XV |
| Import NF-e | Required together with the Duimp and the DIR. A joint act may waive it or provide for automatic issuance from the declaration. The Duimp deadline replaces the NF-e deadline (03/08/2026). | Decree 12.955/2026, art. 113, sole paragraph. Joint Act 4/2026, art. 1, § 3 |
| Time of issuance | At delivery of the goods or at release, whichever comes first. | Decree 12.955/2026, art. 77 |
| Debt acknowledgment | On imports of physical goods, it follows from the information given in the Duimp and the DIR. | Decree 12.955/2026, art. 488 |
| Export NF-e | Supports the DU-E. If the DU-E is amended after endorsement, the Federal Revenue Service sends the Public Digital Bookkeeping System (Sped) an event with the quantity actually exported for each invoice item. | IN RFB 1.702/2017 |
What this asks of tax
Event author
On the import NF-e, the author of the reform events is the issuer, the importer itself. Event 112120, for example, reports an import not converted into an exemption in the Free Trade Areas and the Manaus Free Trade Zone (Technical Note 2025.002-RTC, version 1.40).
Two dates on the same invoice
Customs release and delivery of the goods may not coincide, and the invoice goes out on whichever happens first. Tax depends on someone reporting the delivery, because the CBS deadline follows that date.
Declaration and invoice are separate documents
The Duimp declares the tax, and the inbound NF-e takes the item into inventory and credit. Both must carry the same values, and reconciling them is a close routine.
The flow of the received invoice and its events is in automatic document entry, and the map of documents is in electronic tax documents.
Exports: DU-E, endorsement and proof within the deadline
Exports use the same registry and the same assessment as imports, but the event that completes them is endorsement (IN RFB 1.702/2017 and, for CBS and IBS, LC 214/2025).
Invoice and DU-E
Export clearance is processed through a Single Export Declaration, in the Portal Único. All goods bound for abroad, including re-exported goods, are subject to it (IN RFB 1.702/2017, arts. 1 and 3).
Clearance
Clearance checks the accuracy of the declared data. The final tax classification must be in the DU-E as a condition for endorsement (arts. 4 and 64, § 2).
Shipment
The shipment date depends on the mode: the shipped on board clause for sea, the flight date for air, and border crossing for land and river (art. 85).
Endorsement
Confirms and validates the shipment and bill of lading issue dates, considered for commercial, tax and exchange purposes (art. 89).
Proof
For CBS and IBS, the export is proved within 180 days of issuing the tax document (LC 214/2025, art. 81-A, § 1; Decree 12.955/2026, art. 96).
What tax tracks
- Number of the linked DU-E and NF-e, by item.
- Invoice NCM equal to the final classification in the DU-E.
- Shipment date and endorsement date, which feed the deadline and the exchange rate.
- Quantity exported, including after an amendment of the DU-E.
- Count of the 180 days since the invoice was issued, with an alert before expiry.
- Export service documents with a reference to the invoice for the export of the goods.
If the export is not proved within 180 days, the operation is treated as taxable for consideration, and CBS and IBS are charged with surcharges. The regulation allows an extension of up to another 180 days in situations such as force majeure, an act of authority, a strike and a proven logistics delay (Decree 12.955/2026, art. 96, § 3).
Special regimes: what the rule requires in controls
Each regime creates a control obligation that SAP must support with data, not with a side spreadsheet. The rules come from the Customs Regulation and from Law 11.945/2009. Choosing the regime is the company's decision, with its foreign trade specialist.
Temporary admission
Allows importing goods that stay in the country for a fixed term, with full suspension of tax payment or partial suspension in the case of economic use (RA, art. 353).
Drawback
An export incentive, in the suspension and exemption modalities. Suspension covers the import of inputs for manufacturing a product to be exported, and only a company authorized by the Foreign Trade Secretariat (Secex) may use it (RA, art. 383; Law 11.945/2009, art. 12).
Customs warehouse
Storage of foreign goods in a public-use bonded area, with suspension of federal import taxes, PIS and COFINS-Import (RA, art. 404).
Industrial warehouse (Recof)
Import with suspension, under computerized customs control, of goods that, once manufactured, are meant for export. Part may be cleared for consumption (RA, art. 420).
Suspension by term
Suspension under the special regimes lasts up to 1 year, extendable by the customs authority up to 5 years in total, unless the regime has its own rule (RA, art. 307).
What tax needs to see in the system
- Balance by regime: what came in, what went out and what remains, by item.
- Term of each admission, with an alert before expiry.
- Destination of the goods: export, re-export, consumption or destruction.
- Link between the imported input and the exported product.
- Later operations on the same goods in the same declaration: if the Duimp is registered at admission, the following ones run by Duimp (Portaria Coana 165/2024, art. 16, § 1).
- Person in charge of the regime and of the concession act, by item.
Drawback: one year, one extension, leftovers in 30 days, closing in 60
Calendar of the suspension, according to Portaria Secex 44/2020 (consolidated text of 29/04/2026) and Joint Portaria SECINT/RFB 76/2022, read on 16/10/2026. Deadlines change: check the current text.
Secex and the Federal Revenue Service
Secex grants the act and tracks the export commitment. The Federal Revenue Service controls the customs side and may assess tax and penalties at any time, even after a regular closing.
One year, one extension
The term is one year, counted from approval. A single extension is allowed, requested in Siscomex by the last day of the original term. Long-cycle capital goods have their own rule.
Leftovers within 30 days
If the full export does not happen, the company reports within 30 days of expiry what happens to the balance: return, destruction, consumption with taxes and surcharges, delivery to the Treasury or another regime.
Closing in 60 days
The company requests closing and reports the value of the residues not exported. If there is no request within 60 days of the end of the term, Secex closes it on its own initiative, in whatever state the act is in.
Proof of the cycle
An export counts when the endorsed DU-E is linked to the act and shipment happens within its validity (DU-E Manual, version of 12/07/2026). Each export proves only one act, except in intermediate drawback. The modality is the client's decision.
According to NTT DATA (read on 16/10/2026), the Drawback module of GUEPARDO Global Trade links purchases to the act number. As an Authorized Channel, DFSpro sells the license, implements the module and tracks the act's balance within the client's governance.
Exchange rate, cost and reconciliation: six comparisons
For CBS and IBS, foreign currency is converted at the import duty rate, with no later adjustment for exchange variation (LC 214/2025, art. 70). The IPI base includes the exchange charges paid or due (RA, art. 239).
The accounting treatment of inventory cost and exchange variation belongs to the client's accountant. What SAP tax can guarantee is that the chosen rule is written down and applied the same way on every import.
Reconciliation in six comparisons
Customs value of the declaration
Compare with: the value of the goods on the inbound invoice.
Typical difference: freight and insurance split differently between additions.
Taxes paid at registration
Compare with: the taxes booked on the invoice.
Typical difference: a base component left out, such as the fee or AFRMM.
Exchange rate of the declaration
Compare with: the rate of the payment abroad.
Typical difference: exchange variation treated as cost or as result with no written criterion.
Quantity and NCM of the declaration
Compare with: the quantity and the NCM of the material.
Typical difference: different unit of measure or classification in the master data.
Import cost in inventory
Compare with: the sum of the declaration components.
Typical difference: customs expenses left out of the allocation.
Credit taken
Compare with: the recoverable tax in the declaration.
Typical difference: credit calculated on a base different from the declared one.
What an import really costs
Cost closes when component, base and allocation are written down. Sources read on 16/10/2026: Law 10.865/2004, LC 87/1996, the Customs Regulation and the PGFN page on PIS and Cofins on imports.
One base per tax
A single cascade gets some tax wrong. PIS and Cofins on imports start from the customs value (Law 10.865, art. 7, I). ICMS adds taxes and customs expenses to the value of the goods, with the tax included in its own base (LC 87, art. 13, V and § 1, I).
What comes outside the declaration
The Siscomex fee and AFRMM come from the collection document. Storage, customs broker and domestic freight arrive later, by service invoice. Whether to include port handling in the customs value is a non-constitutional dispute, according to the PGFN: record the position adopted.
Written criterion
Only transport and insurance have a criterion in the rule read: art. 78 of the Customs Regulation (Decree 6.759), which applies when the declaration covers goods of more than one NCM (net weight for transport, value of the goods for insurance). For storage, customs broker and domestic freight, the choice is the client's: record the criterion and apply it the same way on every import.
Spreadsheet against declaration
Each difference against the declaration goes in with its cause recorded, as in question 21. The Siscomex fee and AFRMM change by normative act, and the current validity must be checked in the act.
According to NTT DATA (read on 16/10/2026), the Cost spreadsheet module of GUEPARDO Global Trade makes advance estimates by NCM or overall, without detailing the base of each tax in public: the calculation is proved in the environment. How cost enters inventory is the client's accounting decision. Credits: EFD-Contributions.
CBS and IBS on imports: taxable event, base and payment
CBS and IBS on imports follow LC 214/2025, as worded by LC 227/2026, and CBS has Decree 12.955/2026. The payment deadline follows delivery of the goods, not only clearance. Sources: LC 214/2025 and Decree 12.955/2026.
Incidence
CBS and IBS apply to the import of goods and services by any person, registered or not, whatever the purpose (LC 214/2025, art. 63).
Taxable event
On imports of physical goods, it is the entry into the national territory. For calculation purposes, it is considered to occur at the release of goods submitted to clearance for consumption (arts. 65 and 67).
Place
The place of import is where the goods are delivered to the final recipient, and it must be reported in the declaration (art. 68; Decree 12.955/2026, art. 79).
Payment
By delivery of the goods, even if before release. The taxpayer may bring it forward to the registration of the declaration, and payment is a condition for delivery (art. 76).
Credit
Under the regular regime, the buyer takes credit for what was actually paid on the import (art. 78).
What goes into the tax base
| Component | Included in the base? | Source |
|---|---|---|
| Customs value | Yes, it is the starting point. | LC 214/2025, art. 69 |
| Import Duty and Selective Tax | Yes. | Art. 69, I and II |
| Siscomex fee and AFRMM | Yes. | Art. 69, III and IV |
| Fuel Cide, anti-dumping, countervailing duties and safeguards | Yes. | Art. 69, V to VIII |
| Suframa, health surveillance, Merchant System and agricultural inspection fees | Yes, in the CBS regulation. | Decree 12.955/2026, art. 80, IX to XII |
| Any other taxes, fees and duties up to release | Yes. | Art. 69, IX |
| IPI, ICMS and Service Tax (ISS) | No. | Art. 69, § 2 |
Who answers for the tax
- Taxpayer: the importer and the buyer of warehoused goods. In import on behalf of a third party, the one who brings in the goods is the buyer abroad (art. 72).
- Joint and several liability: whoever registers in its own name the declaration for goods bought by another person, the predetermined orderer, the representative of the foreign carrier and others (art. 74).
- Registration: taxpayers register in the registry for the import obligations (art. 75; Decree 12.955/2026, art. 86).
Intangible goods and services from abroad follow their own rule, based on consumption in the country (art. 64). The exchange rate is the one used for import duty (art. 70).
CBS and IBS on exports: immunity, deadlines and suspensions
On exports, the reform keeps the exporter's credit and creates proof deadlines and conditional suspensions. LC 214/2025 and LC 235/2026 define the rules, and the CBS regulation is in Decree 12.955/2026, arts. 90 to 103 (LC 214/2025, arts. 79 to 83).
Immunity with credit
Exports are immune from CBS and IBS, and the exporter keeps the credit on purchases, with the restrictions of arts. 49 and 51 (LC 214/2025, art. 79).
Deemed export
Immunity also applies to goods that do not leave the territory, such as those incorporated into a good of a foreign buyer who is temporarily in the country (art. 81).
180 days
If the export is not proved within 180 days of issuing the tax document, the operation is treated as taxable for consideration and the tax is charged with surcharges (art. 81-A, § 1).
Specific export purpose
Supply to a commercial exporting company, for the specific purpose of export, may have its payment suspended, with authorization in a joint act (art. 82).
Conversion to zero rate
It becomes zero rate with the actual export. The tax is charged if 180 days pass without exporting, or if the goods are redirected, processed, destroyed or lost (art. 82, §§ 4 and 5).
Requirements for the suspension in art. 82
- Certification in the Authorized Economic Operator (OEA) Program.
- Net equity of at least BRL 1,000,000.00 or one times the value of the suspended taxes, whichever is greater.
- Choice of the Electronic Tax Domicile.
- Accounting books kept and submitted in digital form.
- Tax compliance with the federal, state and municipal administrations.
- Authorization in a joint act of the Federal Revenue Service and the IBS Steering Committee.
Unprocessed agricultural product to an exporting processor
- Payment is suspended on the supply of unprocessed agricultural product to a taxpayer under the regular regime who processes goods for export (art. 82, § 11).
- The minimum percentage of export revenue in the three previous calendar years went from 50% to 30% of total gross revenue (LC 235/2026, art. 6, of August 27, 2026).
- The buyer pays the suspended tax, with surcharges, if within 180 days the product is not processed, or the processed product is neither exported nor sold on the domestic market with tax (art. 82, § 12).
What SAP tax controls
- The export percentage by period, with the revenue base that supports it.
- The date of the supplier's invoice and the count of the 180 days.
- The link between the input received under suspension and the final product.
- The authorization in a joint act, when required.
The 50% figure still appears in art. 99 of Decree 12.955/2026. Whoever tracks this limit should check which text is in force for their operation, with their legal adviser.
Special customs regimes in LC 214/2025
LC 214/2025 treats special customs regimes as payment suspensions, with rules for conversion and for collection when the goods do not meet their destination. Choosing and maintaining the regime are the company's decisions (LC 214/2025, arts. 84 to 104).
| Regime | CBS and IBS treatment | Article of LC 214/2025 |
|---|---|---|
| Customs transit | Payment suspended while the goods are in the regime. | 84 |
| Warehouse regimes | Payment suspended. Does not apply to the certified bonded warehouse, whose goods are considered exported. | 85 and 86 |
| Temporary admission for economic use | Partial suspension: 0.033% of the tax is paid per day of the regime's concession term. | 89, § 1 |
| Processing | Payment suspended, including for goods bought on the domestic market. Recof is considered a processing regime. | 90, §§ 2 and 6 |
| Drawback in the suspension modality | The tax becomes due if the good is not used in the production process of exported goods, or is used in breach of the concession act. | 90, §§ 3 to 5 |
| Drawback exemption and refund | Do not apply to CBS and IBS. | 91 |
| Repetro | Suspension in six modalities, for taxable events up to 31/12/2040. There are terms of 3 and 5 years for destination and conversion to zero rate. | 93 |
| Export processing zones | Imports and purchases with suspension, which becomes zero rate in 2 years if there is no diversion or resale. | 99 to 102 |
Effect on controls
Under the reform, failing to meet the regime's destination costs CBS and IBS, with penalty and interest in several cases. The balance by regime, which was already good practice, now supports the calculation of what is due and when.
The CBS regulation for these regimes is in Title III of Decree 12.955/2026.
NCM and attributes: from master data to the declaration
The most common import error is born in master data: an NCM different from the declared one produces different tax, credit and cost, repeated on every operation. The NCM and the material's tax master data are covered in tax master data, and classification in full, from the table to the invoice, in NCM and tax classification in SAP.
The NCM decides taxes and treatments
Adopted by Brazil, Argentina, Paraguay and Uruguay since 1995, it is the basis for foreign trade taxes, trade defense, valuation and special regimes. It has a little over 10,000 eight-digit codes (Federal Revenue Service).
Attributes by NCM
The New Import Process asks for structured information by NCM code, in the Product Catalog, in the Duimp and in the LPCO. These attributes take the place of the NVE, the highlights and the description fields of the licensing forms (Portal Único Siscomex).
Final classification on exports
In the DU-E, the final tax classification of the goods is a condition for endorsing the shipment (IN RFB 1.702/2017, art. 64, § 2).
What to check in master data
- Material NCM equal to the declaration's, item by item.
- Unit of measure in master data compatible with the declaration's.
- Attributes required for the NCM, kept alongside master data or the Product Catalog.
- NCM change handled as a master data change, with date and owner.
Where customs data reaches the filings
Customs data reaches several filings. In each one, the rule is the same: the value booked must be explainable from the declaration that gave rise to it.
EFD ICMS/IPI
Inbound invoice for imports with IPI and ICMS. On exports, block 1, record 1100, carries the export information.
EFD-Contributions
PIS and Contribution for Social Security Financing (COFINS) credit paid on imports, in the cases of art. 15 of Law 10.865/2004.
ICMS and IPI assessment
Credit and debit of the declaration values, with the deadline for each tax.
CBS and IBS
Duimp as a tax document from 01/01/2027, base of the import and proof of the export.
Twelve test cases and the evidence for each one
Foreign trade testing means running the same case from start to finish and comparing declaration, invoice, cost and assessment.
| Case | What to prove | Evidence to keep |
|---|---|---|
| Import by Duimp, green channel | Values in the declaration, the invoice, the cost and the assessment are equal, component by component. | Duimp statement and postings, side by side. |
| Yellow or red channel | Nothing is booked before release, and delivery is recorded. | Release and delivery dates. |
| Amendment after clearance | The tax difference paid reaches cost, credit and assessment. | Amendment statement and supplementary posting. |
| Import with LPCO | The consenting agency and the license number are kept in the operation's record. | Copy of the LPCO linked to the process. |
| Delivery before release | The invoice goes out on the first date and the CBS deadline follows delivery. | Delivery record and invoice date. |
| Temporary admission | Balance, term and destination controlled until the regime is closed. | Balance and expiry report. |
| Drawback in the suspension modality | Link between imported input and exported product, with the concession act. | Balance report by item. |
| Import on behalf of a third party or by order | Correct taxpayer and liable party on the invoice and the declaration. | Duimp and invoice, with the third-party fields. |
| Regular export | NF-e, DU-E and endorsement with the same NCM and the same quantity. | DU-E statement and invoice protocol. |
| DU-E amendment after endorsement | The exported quantity event reaches the invoice and SAP. | Event recorded on the export NF-e. |
| Export not proved within 180 days | Alert before expiry and handling of the tax due. | List of open invoices by date. |
| Import into an incentive area | Event for import not converted into exemption, when applicable. | Authorized event and value by item. |
Evidence that supports the result
- Declaration, invoice, accounting statement and assessment of the same case, filed together.
- Tax owner and acceptance date for each difference.
- Reconciliation result by component, with the exchange rate used.
Approval criterion: no difference, or an explained difference that the client's tax owner accepts, since the decision is theirs.
Eight errors that show up in the close
Eight situations repeat in import and export environments.
Material NCM different from the declaration
Sign: credit and cost different from expected.
Likely cause: outdated master data.
How to check: compare the NCM of each declaration item with master data.
Cost that does not close
Sign: cost variation at receipt.
Likely cause: allocation of freight, insurance or expenses without the same logic as the declaration.
How to check: rebuild the cost component by component.
Incomplete CBS base
Sign: difference between the calculated value and the declaration's.
Likely cause: fee or AFRMM left out of the base.
How to check: check the items in art. 69 of LC 214/2025.
Invoice issued on the wrong date
Sign: CBS deadline counted from release.
Likely cause: delivery of the goods not reported to tax.
How to check: record the delivery date by process.
Regime with no deadline tracking
Sign: goods admitted more than a year ago still in inventory.
Likely cause: the deadline exists only in a spreadsheet.
How to check: expiry report by regime.
Export with no endorsement in the system
Sign: export invoice left open.
Likely cause: DU-E and invoice not linked.
How to check: list the invoices without endorsement and their issue date.
Exchange rate handled inconsistently
Sign: financial result swinging with no explanation.
Likely cause: different rates between declaration and payment with no criterion.
How to check: write the rule and apply it on every import.
Amendment not reflected
Sign: tax paid too much or too little at the close.
Likely cause: amendment made in the Portal and not in the ERP.
How to check: include the amendment in the reconciliation routine.
Who does what: DFSpro and the client
The boundary exists so that each area knows what it answers for. Risk appears when it is not drawn and data passes from one area to the other without anyone checking it.
What DFSpro does
- Designs the tax path from the declaration to the posting, with the boundary between tax, logistics and foreign trade.
- Configures the tax side of SAP and adapts, in the ABAP programming language, what the process requires.
- Shows the system's behavior with the case matrix, the reconciliation and the difference report.
- Follows the close through to stabilization.
What belongs to the client
- The tax position and the classification of each operation.
- The choice and authorization of customs regimes.
- Clearance, licenses and foreign trade tools.
- Acceptance of each difference found.
Limit of our role
- DFSpro does not decide the tax position or the customs regime: that is the client's.
- It does not do customs clearance or replace the customs broker and the foreign trade area.
- It does not replace the SAP integrator, who keeps the overall architecture and the interfaces.
- Credentials, products and certifications of NTT DATA belong to NTT DATA.
Rules and official sources
Tax reform
Federal Revenue Service and Siscomex
- Portaria Coana 165/2024Federal Revenue Service, Official Gazette of the Union.
- DI switch-off schedulePortal Único Siscomex.
- Integrate your system with the Portal ÚnicoSiscomex.
- Attributes in the New Import ProcessSiscomex.
- IN RFB 1.702/2017, DU-EFederal Revenue Service.
- NCM, Mercosur Common NomenclatureFederal Revenue Service.
Customs and tax legislation
- Decree 6.759/2009, Customs RegulationPlanalto.
- Law 10.865/2004, PIS and COFINS-ImportPlanalto.
- Law 10.893/2004, AFRMMPlanalto.
- Law 11.945/2009, drawbackPlanalto, art. 12.
- Complementary Law 87/1996, ICMSPlanalto.
- Portaria Secex 44/2020, drawbackSiscomex, consolidated text updated on 29/04/2026.
- Joint Portaria SECINT/RFB 76/2022Siscomex, drawback procedure for suspension and exemption.
Blog articles on imports, exports and the Free Trade Zone
Frequently asked questions about foreign trade in SAP
01Has the Duimp already replaced the Import Declaration?+
By operation type, and gradually. The Portal Único Siscomex keeps a schedule that switches off the DI operation by operation, and the LI is not switched off: if it is registered after the switch-off, the system asks for a Duimp. What matters to SAP is knowing which declaration each operation uses.
02How do I know whether my operation already requires a Duimp?+
By the Portal Único schedule spreadsheet, which gives the date by operation type, and by your customs broker. With more than one consenting agency or more than one tax regime, the date is the one when all of them have been switched off.
03Is the Duimp a tax document?+
Yes, for CBS and IBS. Decree 12.955/2026 establishes it as an electronic tax document, and Joint Act RFB/CGIBS 4/2026 sets the start for taxable events from 01/01/2027. The import NF-e is still required together with it.
04What changes for CBS and IBS on imports?+
For calculation purposes, the taxable event is the release of goods submitted to clearance for consumption, and payment runs up to delivery of the goods, even if before release (LC 214/2025, arts. 67 and 76). The base adds the customs value to the entry taxes and fees.
05When is CBS on imports paid?+
By delivery of the goods. The taxpayer may bring it forward to the registration of the declaration, and the difference is charged on the date of the taxable event, without late-payment surcharges. Payment is a condition for delivery (art. 76 of LC 214/2025; art. 87 of Decree 12.955/2026).
06Do ICMS, IPI and ISS go into the CBS and IBS base?+
No. Art. 69, § 2, of LC 214/2025 excludes IPI, ICMS and ISS. What goes in is the customs value, Import Duty, Selective Tax, the Siscomex fee, AFRMM, anti-dumping duties and other taxes and fees up to release.
07Does DFSpro do customs clearance?+
No. The work is in the tax layer of SAP: what the declaration hands to tax, how cost and credit are booked and whether the assessment matches what was declared. Clearance stays with the customs broker and the foreign trade area.
08How does drawback show up in SAP tax?+
As a balance control between the input imported under suspension and the exported product, with the concession act. Under the reform, LC 214/2025 keeps the suspension and rules out the exemption and refund modalities (art. 91). Without data in the system, the balance lives in a spreadsheet.
09Does SAP calculate the import taxes or do they come from the declaration?+
It depends on how the environment is designed, and the rule does not choose for you. What it requires is that the value booked is the one in the declaration. That is why reconciliation, component by component, is the test that decides whether the design is right.
10Is the rule different in SAP ECC and S/4HANA?+
The tax rule for imports is the one in the law, the same for any version. What changes is the integration mechanism for customs data and the tools in each environment, which the integrator and tax design together.
11What are the first signs of a problem?+
Material NCM different from the declaration, import cost that does not close, tax booked differently from the declared one, and goods under a suspended regime with no deadline control. When the regime balance exists only in a spreadsheet, the risk is already in place.
12What does tax need to ask foreign trade for?+
The tax classification of the declaration, the customs value and each tax paid, the entry regime, the exchange rate and the date the goods were delivered. Without these data, the invoice is booked and cannot be explained afterwards.
13How long do I have to prove an export?+
Up to 180 days from issuing the tax document. Without proof, CBS and IBS are charged with surcharges. The regulation allows an extension of up to another 180 days in cases such as force majeure, an act of authority, a strike and a proven logistics delay.
14What changed in the suspension for supplying unprocessed agricultural product?+
LC 235/2026, of August 27, 2026, cut the minimum export revenue percentage of the buying processor from 50% to 30%, measured over the three previous calendar years. Art. 99 of Decree 12.955/2026 still carries the earlier text.
15Does the Duimp require a change in material master data?+
It may. The Duimp asks for attributes by NCM and the classification must match the declaration. Reviewing master data before the operation moves to the Duimp avoids correcting differences one by one later.
16Who should lead the conversation: Tax, Logistics or Foreign Trade?+
All three. Tax answers for booking and assessment, Logistics controls delivery of the goods and Foreign Trade holds the declaration. Since the CBS deadline follows delivery, it helps to define who tells Tax when it happens.
17How does the review connect to the SAP Tax Diagnostic?+
The diagnostic maps where the import cost, credit and bookkeeping differ from what was declared and ranks each point by risk. The result shows whether the next step is a fix to master data, to setup or to the process.
18What does the client decide and what does DFSpro do?+
The client decides the tax position, the customs regime and the acceptance of each difference. DFSpro designs the tax path, configures the tax side of SAP and proves the system's behavior with evidence.
19What happens to leftover input when the act expires?+
If the commitment to export was not met in full, the company reports within 30 days of expiry what becomes of the leftover: return abroad, destruction under customs control, consumption with payment of the suspended taxes and surcharges, delivery to the National Treasury or transfer to another special customs regime. According to Portaria Secex 44/2020 (art. 37, II), input bought on the domestic market allows only payment of the taxes. Basis: Joint Portaria SECINT/RFB 76/2022, art. 18, and Portaria Secex 44/2020, art. 37, read on 16/10/2026.
20When does Secex close the act on its own?+
When the company does not request closing within 60 days after the term has ended. Secex does it on its own initiative, in whatever state the act is in. In DFSpro's reading of art. 40, a difference between authorized balance and actual balance can no longer be fixed by changing the act. A regular closing at Secex also does not stop the Federal Revenue Service from assessing tax later. Basis: Portaria Secex 44/2020, art. 40, and Joint Portaria SECINT/RFB 76/2022, art. 3, read on 16/10/2026.
21Why does the advance spreadsheet not match the declaration?+
Because the spreadsheet estimates and the declaration calculates with the registration data. In practice, the most common causes are a different rate on the registration date, exchange rate, freight and insurance split differently between additions, and expenses that arrive after clearance. Each difference needs a recorded cause, and the advance spreadsheet is a simulation, not a final result.
22Does the PIS and Cofins base on imports include ICMS?+
No. The base is the customs value. The original text of Law 10.865/2004 added ICMS and the contributions themselves, and the STF ruled that part unconstitutional (General Repercussion Topic 1, according to the PGFN, read on 16/10/2026). ICMS goes the opposite way: it adds taxes and customs expenses to its own value (LC 87/1996, art. 13, V).
Start with what tax receives from foreign trade
The first step is an SAP Tax Diagnostic, which checks whether import and export cost, credit and bookkeeping match what was declared, and defines who tells Tax at each event.