Legislation and sources for SAP, GUEPARDO and income taxes: what applies and what the system must record

Business Suite 7: mainstream maintenance until 2027

What it covers

SAP keeps mainstream maintenance for the core applications of Business Suite 7, which includes SAP ERP 6.0 (ECC), until the end of 2027, with no contract change and no extra fee in that period.

Status

Statement of 04/02/2020. On 07/10/2026 SAP confirmed the date again: mainstream maintenance until 31/12/2027.

Watch out if you run SAP

Check the release and enhancement package of your system before you fix the migration window.

At DFSpro. ECC to S/4HANA migration

Optional extended maintenance until 2030

What it covers

From 2028 to 31/12/2030 SAP offers optional extended maintenance for the core applications, at two percentage points above the current maintenance base.

Status

Statement of 04/02/2020, confirmed on 07/10/2026. Whoever wants extended maintenance must decide by the end of 2027.

Watch out if you run SAP

For the tax area, the question is whether extended maintenance includes Brazilian legal changes. Ask SAP for that answer in writing.

Customer-specific maintenance

What it covers

Whoever does not choose extended maintenance by the end of 2027 moves automatically to customer-specific maintenance, with fixes for known problems and no change in fee.

Status

Statement of 04/02/2020. On 07/10/2026 SAP wrote that, for third-party databases and Java, what it delivers under this model is even more limited.

Watch out if you run SAP

SAP wrote that it does not see customer-specific maintenance as a sustainable long-term model for critical systems in these environments.

What expires at the end of 2030

What it covers

SAP's resale and support agreements with third-party database vendors, and SAP support for Java 8/JEE5 on NetWeaver AS Java 7.5, end on 31/12/2030. AS Java 7.5 moves to customer-specific maintenance in 2031, with no later version.

Status

Post by Philipp Herzig, 07/10/2026, on SAP News Center. SAP wrote that the Business Suite 7 dates did not change.

Watch out if you run SAP

According to SAP, converting a Business Suite 7 system on a third-party database to S/4HANA or SAP Cloud ERP is possible only until the end of 2030. After that, only a new implementation.

S/4HANA: maintenance commitment until 2040

What it covers

SAP committed to maintain S/4HANA until the end of 2040.

Status

Statement of 04/02/2020.

Watch out if you run SAP

A maintenance deadline does not say how each release handles Brazilian legal changes. That is in the notes and the localization help for your release.

At DFSpro. Tax calculation in the Brazil localization

The path SAP recommends

What it covers

SAP recommends moving to SAP Cloud ERP and the SAP Autonomous Suite and finishing the transformation by the end of 2030.

Status

SAP's strategic recommendation, in the post of 07/10/2026.

Watch out if you run SAP

The choice between S/4HANA on premise, private cloud or public cloud changes who delivers the tax localization. The design is the client's decision, together with the integrator.

GRC NF-e (SAP NFE 10.0): end of mainstream maintenance

What it covers

SAP Electronic Invoicing for Brazil (SAP NFE, the GRC NF-e) 10.0 is an on-premise product on NetWeaver, with the planned end of mainstream maintenance on 31/12/2025.

Status

Post of 13/04/2023 by an SAP Product and Topic Expert, which points to the Product Availability Matrix to check the date.

Watch out if you run SAP

The official date for your release is in SAP's Product Availability Matrix. Ask in writing what SAP covers after it.

At DFSpro. GRC NF-e and DRC

The successor: outbound and inbound DRC

What it covers

SAP points to SAP Document and Reporting Compliance, in its outbound and inbound options for Brazil, as public cloud services on SAP BTP. SAP handles the communication with the tax authorities' web services.

Status

Post of 13/04/2023. It asks GRC NF-e customers to plan the migration to both options and points to the outbound and inbound migration documentation.

Watch out if you run SAP

Migrating is an implementation project. Plan with the integrator how the two products will coexist and when the cutover will happen.

At DFSpro. GRC NF-e and DRC

Outbound DRC: what the service does

What it covers

Connection to the SEFAZ (NF-e, NF3-e, CT-e and MDF-e) and to the city governments of Rio de Janeiro and São Paulo (NFS-e), with cancellation, correction letter, SVC contingency, number voiding, bulk download, XML by e-mail and signing with a digital certificate.

Status

Feature Scope Description, version 1.0, of 17/03/2025, for SAP ERP, S/4HANA and S/4HANA Cloud Public Edition.

Watch out if you run SAP

NFS-e for other cities requires an extension of the service, according to the document itself. Check what your contract includes.

At DFSpro. Electronic tax documents in SAP

Inbound DRC: received documents

What it covers

SAP's help describes the service that processes received electronic tax documents, with REST APIs, onboarding, security and monitoring, and dedicated pages for SAP S/4HANA and for SAP ERP.

Status

Home page of the service help. SAP post of 31/10/2022: Adobe Forms is needed to generate the PDF of received documents.

Watch out if you run SAP

Before you buy, check which inbound documents the scope covers and how your system connects to the service.

DRC in S/4HANA Cloud: only outbound DRC issues

What it covers

In SAP S/4HANA Cloud, outbound DRC is the only messaging system available for NF-e (model 55) and for NFS-e of São Paulo and Rio de Janeiro. For NFS-e of other cities there is the Partner Enablement option, with its own solution.

Status

SAP post of 31/10/2022, which sums up recommendations published in SAP's help.

Watch out if you run SAP

Whoever considers the public cloud must first map each NFS-e city in their records.

At DFSpro. Electronic tax documents in SAP

Reporting DRC on Neo and DRC Cloud Edition

What it covers

The statutory reporting DRC service on the Neo environment has been deprecated since December 2024: there is no renewal, but it can be used until the subscription ends. The alternative is DRC Cloud Edition with S/4HANA Cloud Public or Private Edition.

Status

SAP help. Data analysis with SAP Analytics Cloud will be deprecated on 31/12/2025. According to an SAP post, Cloud Edition runs on SAP BTP, independent of the ERP release cycle.

Watch out if you run SAP

To extract audit data after the contract ends, SAP tells you to open an incident on component LOD-LH-ACR before it is over.

Timeline as SAP describes it

What it covers

2026: test year, with CBS at 0.9% and IBS at 0.1%. 2027: CBS replaces PIS and Cofins, and IPI goes to zero, except in the Manaus Free Trade Zone. 2028: last year of ICMS and ISS unchanged. 2029: 10% yearly reduction in ICMS and ISS. 2033: full regime.

Status

SAP post of 02/11/2025. SAP asks for solutions implemented and tested by December 2025.

Watch out if you run SAP

The legal deadline comes from the rule, LC 214. SAP's timeline sums up what SAP delivers.

At DFSpro. CBS and IBS tax reform

SAP notes and support channels

What it covers

Note 3561376 (the lead note, with the XML for Note Analyzer), note 3637842 (testing limits with the SEFAZ), KBA 3642384 (troubleshooting guide), note 3200109 (Note Analyzer), the Brazil localization SAP Work Zone and Regulatory Change Manager.

Status

SAP post of 02/11/2025. The notes and the KBA are updated often, and reading them requires an S-user.

Watch out if you run SAP

Which notes are implemented in your system is measured in your environment, with Note Analyzer.

How SAP asks for the notes to be implemented

What it covers

Use Note Analyzer with the XML attached to the lead note, follow the implementation order shown in the comments column, read the text of each note, and do not move on with an earlier note incomplete.

Status

SAP guidance in the post of 02/11/2025. The tool shows the order, but not the full list of prerequisites.

Watch out if you run SAP

A note left half done corrupts the system, according to SAP. Record the status of each note before you go on.

Validation at the SEFAZ, as SAP described it

What it covers

SAP wrote that the SEFAZ test environment already accepted the new NF-e fields and that, from January 2026, filling them in would be mandatory in production, with a risk of rejection.

Status

SAP post of 02/11/2025: until January 2026 the fields were optional and, if filled in, should not cause rejection.

Watch out if you run SAP

The date and the rejection rule come from the technical note and the manual of each document, not from the post.

At DFSpro. Electronic tax documents in SAP

CBS and IBS tax situation in purchasing and goods movement

What it covers

The help links the CBS and IBS tax situation to the price structures of purchasing and goods movement. The field becomes part of structure J_1B_TAXCOM, the setup is in note 3694434 and the component is FI-LOC-MM-BR.

Status

Applies to S/4HANA and S/4HANA Cloud Private Edition, from 2025 FPS02, 2023 SPS06, 2022 SPS08, 2021 SPS10, 2020 SPS12, 1909 SPS14, 1809 SPS16 and 1709 SPS18. In releases up to 2023 FPS01, availability in the private cloud depends on the contract.

Watch out if you run SAP

Whoever is on these releases or above does not need to implement the note, according to SAP. For ECC, the page does not apply.

At DFSpro. Tax calculation in the Brazil localization

SAP help pages for CBS, IBS and presumed credit

What it covers

Titles in the localization help: tax groups and tax types on the invoice, CBS and IBS as statistical values, tax situation in sales and purchasing, calculation base in TAXBRA, TAXBRJ, RVABRA and RVXBRA, NBS in purchasing, BAdI and nominal rate in the Nota Fiscal Writer.

Status

List published in the S/4HANA help, which also has CBS and IBS fields for single-phase fuels and fields for presumed credit and tax benefit code.

Watch out if you run SAP

Each title has its own availability release. Compare it with the release of your system before you plan.

GUEPARDO Tax scope

What it covers

A solution for municipal, state and federal tax obligations, conceived as a component of the SAP system, with a tax management dashboard and a single database for assessments and compliance.

Status

Text from the product page, stated by NTT DATA, owner of GUEPARDO Tax.

Watch out if you run SAP

Versions, release notes and what the product does for each article of LC 214 are requested in writing from NTT DATA.

At DFSpro. GUEPARDO Tax

Stated features

What it covers

Assessment, file generation, payment slip management, credit control, a tax calendar with deadlines and owners, reports in the SPED format, pre-validation before audits, and validation with tax planning and tax recovery.

Status

List from the product page, stated by NTT DATA.

Watch out if you run SAP

A stated feature is proven in your system, with your data, before it becomes a project assumption.

GUEPARDO seals and certifications

What it covers

Compatibility with S/4HANA Cloud Private Edition, the SAP DRC seal, the SAP TDF certification, ISO 27001, ISO 27017 and SOC 2 Type II.

Status

List from the product page. NTT DATA states it has led SAP certification for tax solutions since 2009.

Watch out if you run SAP

These are credentials of the NTT DATA product, not of DFSpro.

CBS pilot with the Federal Revenue Service

What it covers

NTT DATA and GUEPARDO were invited by the Federal Revenue Service to the CBS pilot, among fewer than 400 companies selected out of over 23 million active ones, with early access to APIs, layouts and rules from the Revenue Service and Serpro. The enrollment is recorded in the Federal Official Gazette.

Status

NTT DATA post of 08/10/2025.

Watch out if you run SAP

This achievement belongs to NTT DATA, and has no relation to DFSpro.

GUEPARDO Tax simulation calculator

What it covers

It projects tax reform scenarios and provides 80/20 reports: suppliers with the largest credits, the most affected customers, products and services with the largest tax effect, and the most sensitive tax domiciles.

Status

NTT DATA description in a post of 04/11/2025.

Watch out if you run SAP

A simulation is not an assessment, and what to do with the result is the client's decision.

GUEPARDO Update Service

What it covers

A tax support service from NTT DATA Brazil for customers who already have GUEPARDO Tax: new features and obligations, technical and functional requests, adjustments and setup, SAP support with the Brazil localization, and a team with SAP PCoE certification.

Status

Service page. The steps described run from validating the key obligations and generating evidence to release for customer testing.

Watch out if you run SAP

Scope and terms are confirmed with NTT DATA. DFSpro's AMS Fiscal is a different instrument.

Law 14.789/2023: subsidy tax credit

What it covers

A company on actual profit that receives a subsidy from the Union, a State, the Federal District or a Municipality to set up or expand a business can assess a tax credit of 25% on subsidy revenue (arts. 1 and 6), assessed in the ECF of the period.

Status

In force, with effects since 01/01/2024 (art. 22).

Watch out if you run SAP

The system must separate subsidy revenue by grant act and reconcile it with the amount carried to the ECF.

At DFSpro. State tax benefits in SAP

Enrollment in the subsidy credit regime

What it covers

The Revenue Service enrolls a company on actual profit that has joined the Electronic Tax Domicile, has regular CNPJ and tax standing, has EFD ICMS/IPI and EFD-Contribuições up to date, issues NF-e between establishments, and has had no special inspection regime in the last three years.

Status

gov.br service updated on 28/08/2026: estimated time of up to 30 calendar days and appeal within 10 days. Law 14.789 (art. 4) requires a grant act before the set-up or expansion.

Watch out if you run SAP

EFD and NF-e are enrollment requirements. The quality of these files in SAP affects the benefit.

Subsidy credit: assessment, use and change by LC 214

What it covers

Only revenue tied to set-up or expansion and recognized after the request was filed counts (art. 7). Reimbursement happens in the 24th month, if not offset (art. 10). A credit assessed outside the law is not recognized (art. 12). LC 214 changed arts. 11 and 17 (art. 534).

Status

The text of Law 14.789 on Planalto still shows art. 11 in its earlier wording, which also cited PIS and Cofins. Art. 526 of LC 214 changes art. 30 of Law 12.350/2010.

Watch out if you run SAP

Read Law 14.789 and LC 214 together. Keep, by period, the filing date and the eligible revenue.

Law 14.596/2023: transfer pricing

What it covers

The terms of a controlled transaction with a related party follow those that independent parties would set in comparable transactions (art. 2). The taxpayer selects the most appropriate method, among PIC, PRL, MCL, MLT, MDL and others (art. 11).

Status

In force since 01/01/2024 (art. 47), with an irrevocable option to apply it from 01/01/2023 (art. 45).

Watch out if you run SAP

The system must flag the related party and keep the chosen method. The client chooses the method.

At DFSpro. Foreign trade in SAP

Transfer pricing: documentation and fines

What it covers

The Master File and the Local File are mandatory for controlled transactions of BRL 15,000,000.00 or more in the previous year, before adjustments. Between BRL 15 million and BRL 500 million, the Local File can be simplified, under IN RFB 2.161/2023 (art. 57, II).

Status

gov.br service updated on 28/07/2026. Law 14.596 sets fines from BRL 20,000.00 to BRL 5,000,000.00 (art. 35) and limited amendment during a tax procedure (art. 36).

Watch out if you run SAP

The system must separate compensating adjustments from voluntary adjustments and reconcile the ledger with the file delivered.

LC 214/2025: compensation for onerous ICMS benefits

What it covers

Holders of onerous ICMS benefits are compensated between 01/01/2029 and 31/12/2032, with funds from the Compensation Fund (art. 384). Art. 386, IV, tells the Revenue Service to define the bookkeeping, and art. 401 gives the amounts received the same treatment as the State's benefit for IRPJ, CSLL, PIS and Cofins.

Status

Consolidated text from Planalto, with later changes. Art. 402 creates a working group of the Finance Departments and the Revenue Service that proposes changes to the ancillary obligations.

Watch out if you run SAP

Keep, by period, the amounts compensated and the matching benefit, for the bookkeeping the Revenue Service may define.

At DFSpro. ICMS compensation fund, on the blog