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Sector · Wholesale and E-commerce

Wholesale and e-commerce in SAP: destination state, platform and high-volume invoicing

A wholesaler sells to many states, with ICMS-ST and transfers between distribution centers. An e-commerce seller ships to consumers in other states and shares the sale with a platform. In both cases, the rule changes with the destination of the goods and with who is on the other side of the invoice.

This page covers what we read in official sources: interstate ST, DIFAL on sales to final consumers, platform liability, returns and the move to IBS and CBS. Where we did not open the source, it says "not checked". ICMS is Brazil's state value-added tax. ST (tax substitution) means one party withholds the tax for later sellers in the chain. DIFAL is the difference between the destination and origin rates.

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Tax map

Six points where wholesale and e-commerce pay more for mistakes

The legal basis column lists only rules we opened and read on 19/10/2026. The break column is DFSpro's judgment. Dates use the Brazilian day/month/year format.

To start the conversation: does your CFOP and CEST master data already separate, by distribution center (CD) and destination state, what is ST, what is DIFAL and what is a transfer?

The short answer: if it separates them, each invoice is born with the tax in the right state. If not, the starting point is to test the CFOP and CEST rules on one month of sales and transfers, state by state.

TopicRule that hits the sector hardestLegal basis (read)Where it tends to break (judgment)
ICMS-ST on interstate salesThe sender can be responsible for withholding the tax on later operations, owed to the destination state, for goods listed in an agreement or protocol.ICMS Agreement 142/18, clause 8Goods with an outdated CEST or NCM: too much tax withheld, too little, or none.
Transfers between distribution centersSince 2024, a shipment to an establishment of the same owner is not a taxable event, and the credit is kept. The taxpayer may choose to tax it. ST does not apply to the transfer, unless the destination is a retailer.Complementary Law (LC) 204/23 (art. 12, §§ 4 and 5 of LC 87); ICMS Agreement 142/18, clause 9, IIOld taxed-transfer rule still active in the CFOP master data.
DIFAL on sales to final consumersThe sender pays the difference between the destination's internal rate and the interstate rate, by GNRE or state payment slip, at shipment and per operation.LC 190/22; ICMS Agreement 236/21, clauses 1, 2 and 5Payment slip that does not match the invoice; poverty fund surcharge left out of the base.
Digital platformA platform that controls billing, payment, terms or delivery may be liable for IBS and CBS, together with the supplier, in defined cases.LC 214/25, art. 22 (consolidated text with LC 227/26)Who is the supplier, who is the platform and who issues the invoice is not in the master data.
Returns and exchangesFor IBS and CBS, the base and rate of a return are those of the original operation. The right of withdrawal runs for 7 days on purchases made outside the store.LC 214/25, arts. 12, § 7, and 17; Consumer Code (CDC), art. 49Partial return with no link to the sales invoice.
IBS, CBS and split paymentIn 2026, test rates for IBS and CBS apply, and they can be offset. With split payment, the tax is separated when the payment is settled.EC 132/23, ADCT arts. 125, 126 and 129; LC 214/25, arts. 31 to 35Payment through a platform, which becomes part of the tax calculation.

Physical retail and the NFC-e (the retail consumer invoice) have their own page: see Distribution and Retail. Here the focus is wholesale and distance selling.

Index

Choose your entry point by your role

Four entries, one per role, straight to the block that answers your question.

01Tax and finance

Interstate ST, transfers and wholesaler regimes, with the legal basis read in official sources.

Go to section

02IT and SAP integrator

Six setup points that the tax team sees first.

Go to section

03Management and decisions

Where tax processes in wholesale and e-commerce become a project, and how the diagnostic, the project and AMS Fiscal work.

Go to section

04Online sales and marketplace

How the tax is split on a sale to a consumer in another state, and what changes when the platform is liable for the tax.

Go to section
Direct links
Direct links:six risk pointsmarketplacereturnsreform and split paymentincentivesrules readfilingsquestions
Wholesale

Interstate ST, transfers and wholesaler regimes

What the official source we read says, and what was left out.

Who withholds on an interstate sale

ICMS Agreement 142/18, clause 8, says that a sender who makes an interstate operation with goods covered by an ST agreement or protocol may be responsible for withholding and paying the ICMS on later operations, owed to the destination state (UF). The same clause covers the rate difference on goods bought by the recipient for its own use, consumption and fixed assets.

Where ST does not apply

Clause 9 removes the regime, unless provided otherwise, on an interstate sale to an industrial establishment that makes the same good, and on a sale to an industrial buyer for use as input, as long as it does not trade the same good. It also removes transfers between units of the same sender, except to a retail unit.

ST calculation base

Clauses 10 and 11: the starting point is the final price set by a public body. If there is none, the destination state defines the path: PMPF, the final price suggested by the producer or importer, or the sender's price plus freight, insurance and charges, increased by the MVA. For a sender under the Simples regime, there is a specific MVA rule.

The CEST has seven digits: the first two show the segment, the next three the item and the last two the specification (clause 6). The list of goods under ST is in the agreement's annexes, by segment (clause 7 and Annexes II to XXVI). Without the correct CEST and NCM in the master data, the withholding cannot come out right.

Transfers between establishments

LC 204/23, in force since 01/01/2024, added § 4 to art. 12 of LC 87/96: a shipment to another establishment of the same owner is not a taxable event for ICMS, and the credit from earlier operations is kept. With § 5, enacted after the veto was overridden, the taxpayer can choose to treat the transfer as a taxed operation. Form and deadline for the choice: not checked.

Simples Nacional taxpayers

Art. 13, § 1, XIII, of LC 123/06 covers the ICMS that the Simples single payment does not include. It is the ICMS due on operations under ST, single-stage taxation and advance payment that ends the taxation. It applies to the product lists in the text (including drinks, medicines, cosmetics, perfumery, personal hygiene, vehicles and parts, electronics and appliances) and to door-to-door sales. In those cases, the rules for other companies apply. How this applies to each wholesaler and each product: not checked.

Not checked

Grant acts and special regimes for wholesalers in each state (presumed credit, deferral), interstate rates set by the Senate, ST protocols by product, MVA and PMPF by state, and the list of items in each annex. None of these points is stated as fact.

For ST and DIFAL in the calculation, see ICMS-ST and DIFAL in SAP.

DIFAL and distance selling

From the consumer in another state: split, base and payment slip

For sales to a non-taxpayer located in another state.

MilestoneWhat the source we read says
EC 87/2015, ADCT art. 99Split the rate difference between origin and destination, with the destination's share at 20% (2015), 40% (2016), 60% (2017) and 80% (2018), and 100% from 2019.
LC 190/2022, new wording of art. 4, § 2, of LC 87The taxpayer for the rate difference is the sender, when the recipient is not an ICMS taxpayer, and the recipient, when it is one.
ICMS Agreement 236/21, clause 2The sender calculates the total tax with the destination's internal rate, calculates the amount due to the origin with the interstate rate, and pays the difference to the destination.
ICMS Agreement 236/21, clause 2, § 4The surcharge of up to two percentage points for poverty-fighting funds is part of the calculation, and payment follows the legislation of the destination state.
ICMS Agreement 236/21, clauses 4, 5 and 6Electronic tax document; payment by GNRE or state payment slip, at shipment, per operation. If the destination state requires registration, the deadline is the 15th of the following month.

In each destination state, the design of the payment slip, the registration and the treatment of Simples Nacional vary. This state-level detail was not checked and is left out.

DFSpro's reading, not a legal provision

The DIFAL in LC 190/22 deals with final consumers. A transfer between establishments of the same owner is not delivery to a final consumer. Whether that is the position for each case is the client's decision.

Marketplace

When the platform is liable for the tax

LC 214/25, art. 22, consolidated text with the changes of LC 227/26, read on 19/10/2026.

What a digital platform is

One that acts as an intermediary in a remote or electronic operation and controls one or more of these elements: billing, payment, terms and conditions, or delivery (art. 22, § 1). A party that only provides internet access, provides an authorized payment service, advertises, or compares suppliers without charging for sales is not a platform (§ 2).

When it is liable

It is liable for the IBS and CBS on operations made through it. With a supplier abroad, it is liable together with the buyer and in the buyer's place. With a supplier in Brazil, it is jointly liable in cases that include not providing the information in § 5, or a taxpayer supplier not issuing an electronic tax document for the value of the operation.

What the platform must provide

Information on the operations and on the supplier to the IBS Management Committee and to the RFB, the Brazilian Federal Revenue Service (§ 5) and, when it starts the payment, the data for split payment (§ 6). When it meets these conditions, it is not liable for payment differences of a supplier resident in Brazil (§ 7).

What the platform may choose

With the supplier's consent, issue electronic tax documents in the supplier's name and pay the tax (§ 12), or act as tax substitute (§ 13). It is not liable when it controls none of the essential elements (§ 11).

Not checked

The regulation by the Management Committee and the RFB on the format of the information, who is liable for ICMS in a marketplace before the Reform, and the rules of each state. Nothing about them is stated as fact.

Returns and exchanges

What the law we read says, and what SAP needs to keep

Two layers: consumer law and the invoice.

LayerSource readWhat it says
Right of withdrawalConsumer Code, art. 49For a contract made outside the store, the consumer can withdraw within 7 days of signing the contract or receiving the product. The amounts paid are refunded right away, with adjustment.
E-commerceDecree 7,962/13, art. 5The supplier states clearly how to use the right of withdrawal. The request is confirmed right away and reported to the card issuer, so the charge is not posted or is reversed.
IBS and CBSLC 214/25, arts. 12, § 7, and 17On a return or cancellation, the calculation base and rate are those of the original operation.
Credit on returnLC 214/25, art. 47, § 8 (wording of LC 227/26)If the buyer is not a taxpayer in the regular regime, the supplier may take a credit or reverse a debit based on the debits of the returned or canceled operation.
NFC-e and NF-eSINIEF Adjustment 07/05, clause 3, § 9Effective 14/12/2026, an outbound NF-e that refers to an NFC-e is not allowed, except a complementary NF-e.
ICMS-ST undoneICMS Agreement 142/18, clause 16Deals with the undoing of the deal. The full text of the clause and the rules in each state: not checked beyond the reading of clause 15.

How each state treats the issue of the return invoice from the consumer and the matching ICMS credit: not checked.

Tax Reform

From 2026 to 2033, with split payment in the middle

Figures from EC 132/23 and LC 214/25, read on 19/10/2026.

2026

Test rates of IBS 0.1% (art. 343) and CBS 0.9% (art. 346). A taxpayer that is up to date with its ancillary obligations does not have to pay (art. 348, § 1), and PIS and Cofins stay in full (§ 2). Simples taxpayers are left out (art. 348, III, c). Anyone who pays can offset against PIS and Cofins or, with no debit, against another federal tax or get a refund within 60 days.

2027 and 2028

In 2027 and 2028, IBS adds 0.05% for the state and 0.05% for the city (art. 344), and CBS at the set rate minus 0.1 percentage point (art. 347). PIS and Cofins no longer exist.

2029 to 2032

ICMS reduced by 10%, 20%, 30% and 40% (LC 214, art. 501, which adds art. 31-A to LC 87/96). IBS rates by year: not checked.

2033

IBS and CBS in full. ICMS and ISS end (ADCT, art. 129).

Split payment requires payment service providers to separate and pay IBS and CBS when the payment is settled (LC 214, art. 31). There is a standard procedure (art. 32) and an optional simplified procedure for operations where the buyer is not a taxpayer in the regular regime (art. 33). Rollout is gradual (art. 35). For anyone selling through a platform, payment is no longer only a financial step and now matters for the tax calculation.

More in Tax Reform: CBS and IBS, split payment in SAP and CST of the Reform.

State incentive

Presumed credit and ICMS incentives for wholesalers: deadline and transition

Texts of LC 160/17, LC 186/21, ICMS Agreement 190/17 and LC 214/25, read on 22/10/2026.

Benefit period

LC 160/17, art. 3, § 2, limits the use of a benefit reinstated by agreement. For keeping or increasing commercial activity, as long as the beneficiary is the actual sender of the goods, the period runs to December 31 of the fifteenth year after the agreement takes effect (wording of LC 186/21; the original text said the fifth year). From the twelfth year, § 2-A requires the benefit to fall by 20% a year, but ADCT art. 128, § 2 (EC 132) says that, from 2029 to 2032, the benefits of art. 3 of LC 160 follow the reduction of 9/10 to 6/10 of the ICMS, and the reduction in § 2-A does not apply.

Registration with Confaz

Art. 3 of LC 160 requires each state to publish the list of acts, and to register and file with Confaz, the national council of state finance secretaries, the documents of the grant acts, which go to the National Tax Transparency Portal. Without this, § 1 requires the grant acts to be revoked. ICMS Agreement 190/17 repeats the conditions (clause 2) and creates the portal (clause 7).

Compensation from 2029 to 2032

LC 214, art. 384, compensates through a fund the holders of onerous benefits between 01/01/2029 and 31/12/2032. It applies to benefits granted in due form up to 31/05/2023, with a term up to 31/12/2032, registration and filing under art. 3, II, of LC 160 where applicable, and the conditions of the act met. Item III of the sole paragraph leaves out the benefits of § 2-A of art. 3 of LC 160.

For LC 214, an onerous benefit is one granted for a fixed term and under conditions, as in art. 178 of the National Tax Code (CTN) (art. 385). The request to join the compensation is filed with and reviewed by the Federal Revenue Service, which sets the form and the information (art. 386).

DFSpro's judgment

Before any design work, the wholesaler needs to know which act grants the benefit, whether it was registered with Confaz, which term is running and whether it is onerous. How each benefit fits in the compensation, or outside it, is for the client and its legal team to read. Our work starts after that decision: model the benefit in the system and prove the result.

Not checked

Which states registered wholesale benefits and on what conditions, the date the agreement took effect that sets the fifteenth year in each case, the criteria to measure the level of the benefit beyond arts. 384 to 386, and the regulation on joining the compensation at the Federal Revenue Service.

Sector legislation

Rules read, with their status on 19/10/2026

Each line was opened on the official site. What we did not open is listed right below the table.

RuleSummaryStatus
ICMS Agreement 142/18 (14/12/2018)ST regimes and advance payment that ends the taxation.In force; the list of changes goes up to Agreement 107/26. Clauses 5 to 11, 15 and 16 read.
Complementary Law 87/96 and LC 204/23The Kandir Law; LC 204/23 added §§ 4 and 5 to art. 12.In force. LC 204/23 has applied since 01/01/2024.
Constitutional Amendment 87/15Changes art. 155, § 2, and adds art. 99 to the ADCT: split of the rate difference.Split from 2015 to 2018; 100% to the destination since 2019.
Complementary Law 190/22 (04/01/2022)Changes LC 87/96 for ICMS on interstate sales to final consumers.In force. Effects follow the prior-year rule of art. 150, III, "c", of the Constitution (CF).
ICMS Agreement 236/21 (27/12/2021)DIFAL procedures for sales to final consumers who are not taxpayers.In force in the version read. It revoked ICMS Agreement 93/15 (effective 01/01/2022).
SINIEF Adjustment 07/05 (30/09/2005)Creates the NF-e and the DANFE.In force, changed up to Adjustment 40/26. Clause 3, § 9 read (effective 14/12/2026).
SINIEF Adjustment 19/16 (09/12/2016)Creates the NFC-e, model 65.In force, with changes. Details on the Distribution and Retail page.
Law 8,078/90, art. 49, and Decree 7,962/13Right of withdrawal and e-commerce.In force in the consolidated version read.
Complementary Law 160/17 and LC 186/21Forgiveness and reinstatement of ICMS benefits by agreement; LC 186/21 extends the terms.In force in the consolidated version read. Arts. 1 to 3 and the wording of LC 186/21 read.
ICMS Agreement 190/17Forgiveness, amnesty and reinstatement of ICMS tax benefits.Clauses 1, 2, 7, 8 and 9 read. Later changes beyond those noted in the text: not checked.
Complementary Law 123/06, art. 13, § 1, XIIIICMS outside the Simples single payment in ST, single-stage taxation and advance payment.Consolidated text read on 22/10/2026, with the link to LC 214/25 and the start of its effects: not checked.
Constitutional Amendment 132/23Reform of the national tax system.In force. Transition from 2026 to 2033.
Complementary Law 214/25 and LC 227/26Creates IBS, CBS and the Selective Tax; LC 227/26 changes LC 214.In force, in the consolidated version read. Arts. 12, 17, 22, 31 to 35, 47, 343 to 348 and 384 to 386 read.
Not checked

EFD Contributions, ECD and ECF, Senate Resolutions on interstate rates, special regimes of each state and the split payment regulation.

What breaks in SAP

Six setup points that the tax team sees first

DFSpro's judgment, based on the rules above. The SAP base installed in this sector: not checked.

CEST and NCM in the wholesaler's master data

Symptom: ST withheld too low or too high on an interstate sale. Proof: report of items under ST by destination state, against the agreement annex.

Transfers between centers

Symptom: ICMS shown on a transfer that the 2024 rule does not tax, or a credit that does not arrive. Proof: transfer invoices by CFOP and by period.

DIFAL on online sales

Symptom: payment slip different from what the invoice calculated, poverty fund surcharge left out. Proof: payment slip per operation against the tax document.

Platform and supplier master data

Symptom: the system does not tell own sales from intermediated sales. Proof: map of orders by channel and by invoice issuer.

Return with no link to the sale

Symptom: credit or reversal that does not match the original invoice. Proof: return by item linked to the sales invoice, with the original base and rate.

Payment and tax calculation in parallel

Symptom: split payment goes one way and the IBS and CBS calculation another. Proof: table by period and by payment method.

Extra point: state incentive

Symptom: presumed credit applied in the calculation with no grant act identified in the master data, and no term. Proof: list of benefits by CNPJ and state, with the act, the Confaz registration and the validity, against what the system applies.

Where DFSpro solves it

Six wholesale and e-commerce points that DFSpro solves in SAP

From the distribution center to the platform order, each point is configured with the rule the client chose and proven in testing before it goes to production.

Transfer

Between DCs, without tax for nothing

A transfer between establishments of the same owner stopped being an ICMS taxable event, with an option to tax it, and many systems still follow the old rule. DFSpro maps the routes, configures the client's choice and tests each one.

AMS Fiscal

ST in many states, no surprises

Each destination asks for its own registration, payment slip and deadline, and a delay can suspend the agreement there. The AMS Fiscal tax health report lists states, registrations and status, with every change recorded and approved.

Marketplace

Own sales and platform sales kept apart

Under LC 214, whoever controls billing and payment becomes part of the evidence. DFSpro records each partner's role in the master data and in the order, and tests whether the invoice goes out with the right supplier.

Incentive

Presumed credit with backing and a term

The wholesale incentive depends on an act registered with Confaz and on a benefit period, and compensation starts in 2029. DFSpro lists the benefit by CNPJ and state and puts it on the calendar. Whether to use it is the client's decision.

Returns

Return tied to the original sale

The base and rate of a consumer return follow the original operation, which needs the original invoice. DFSpro builds the flow with that reference and tests partial and full returns, so finance and tax close together.

CEST

Complete master data, correct ST

A new item without a CEST falls outside ST. DFSpro designs the NCM, CEST and segment link with validity dates and proves the withholding by state, so a new master record does not become an error in the tax calculation.

Request the SAP Tax Diagnostic
Ancillary obligations

What the sector files, and who requires it

Deadlines depend on the state and the regime. Where the source we read gives no deadline, the line says so.

ObligationWhat it isWho requires it and how often
NF-e, model 55Invoice for sales between companies, transfers and interstate sales to consumers.SINIEF Adjustment 07/05. DIFAL requires an electronic tax document (Agreement 236/21, clause 4).
NFC-e, model 65Invoice for in-person sales to the final consumer.SINIEF Adjustment 19/16, as on the retail page.
GNRE or DIFAL payment slipPayment to the destination state, per operation.Agreement 236/21, clause 5, at shipment. With registration in the destination state, by the 15th of the following month (clause 6).
GIA-ST, DeSTDA and ST fileInformation on tax substitution.ICMS Agreement 142/18, clause 21: the 15th of the following month applies only to the magnetic file of taxpayers not required to file the EFD (item III). The other items (GIA-ST, the Simples DeSTDA and the price list in XML within 30 days) have their own deadlines.
Platform informationOperations and supplier data, sent to the IBS Management Committee and to the RFB.LC 214/25, art. 22, § 5. Form and deadline in the regulation: not checked.
EFD ICMS/IPIBookkeeping of ICMS and IPI.Practical Guide on the SPED portal. Deadline: not checked.
EFD Contributions, ECD and ECFFederal bookkeeping files.Not checked in this research.

For all the filings in SAP, see ancillary obligations and SPED and SPED Fiscal in SAP. The legal basis is in SPED and ancillary obligations legislation, and the filing dates are in the tax calendar.

Sector situations

Where tax processes for wholesale and e-commerce in SAP become a project and DFSpro shortens the path

Distribution centers full of equipment, stock inside marketplaces, returns in volume, thousands of documents a day. In wholesale and e-commerce, scale turns details of master data and of the close into a project.

16sector situations where the tax process becomes a project
  • Fixed assets (2)
  • Special stock (3)
  • Reverse logistics (1)
  • Credits (3)
  • Unit of measure (1)
  • Stock (1)
  • Reform (2)
  • Close (1)
  • Migration (1)
  • Accounting and tax (1)

The legal basis of each situation is an official source read on 23/10/2026. The SAP design is DFSpro's judgment, to be checked against each company's system version. No savings were measured.

01Fixed assets

Distribution center: conveyors, forklifts and racks as fixed assets

What weighs: Many small, similar assets, bought in batches, with ICMS and PIS and Cofins credits running for each asset.

What DFSpro changes: Batch registration of the asset with a ready tax depreciation area, CIAP and reconciliation with FI-AA.

See the situation, the legal basis and the proof

The situation

Wholesalers and e-commerce operations expand distribution centers with conveyors, forklifts, racks, cold rooms and picking systems. They arrive in large shipments, often on a single invoice with dozens of items.

Legal basis, line by line

  • LC 87/1996: art. 20, § 5: installments of 1/48, ratio of taxed outbound sales and cancellation at the end of the 48th month
  • Law 10,833/2003: art. 3, § 1, III and § 14: credit on depreciation or, as an option, 1/48 on machinery
  • EFD-ICMS/IPI Practical Guide, version 3.2.1 (updated 28/10/2025): G110 (CIAP balance and installments), G125 (movement of an asset or component) and G130 (tax document)
  • CPC 27 (R1), rev. 14, CVM: item 43: a significant cost component is depreciated separately

Proof delivered

Reconciliation of invoice, asset record, CIAP installment and G110 and G125 records, with expected and obtained values per asset.

02Fixed assets

Renovation and improvements in a leased warehouse: amortize over the lease term

What weighs: The work belongs to the company and the property does not, so the amortization term, the credit and the write-off depend on the contract.

What DFSpro changes: Improvement asset with a term tied to the contract and automatic write-off when the contract ends.

See the situation, the legal basis and the proof

The situation

Distribution centers and wholesale stores sit in leased property, where the tenant installs docks, mezzanines, air conditioning and fire protection.

Legal basis, line by line

  • Law 10,833/2003: art. 3, § 1, III and VII: credit on depreciation and amortization charges of buildings and improvements on third-party property
  • CPC 27 (R1), rev. 14, CVM: items 51 and 67: yearly review of useful life and write-off

Proof delivered

Record of each improvement with term, monthly installment and balance, reconciled with the contract and with the credit booked.

03Special stock

Stock inside the marketplace and the logistics operator

What weighs: The goods are yours, they sit in someone else's warehouse and the balance changes every day without an invoice for each movement.

What DFSpro changes: Stock held by third parties designed, with shipment, return and inventory reconciled.

See the situation, the legal basis and the proof

The situation

E-commerce sellers send goods to the distribution centers of platforms and logistics operators, who pick and deliver them.

Legal basis, line by line

  • Civil Code (Law 10,406/2002): arts. 627 to 629: deposit contract, custody and return by the depositary
  • EFD-ICMS/IPI Practical Guide, version 3.2.1 (updated 28/10/2025): H010, field IND_PROP, and K200 by participant
  • LC 214/2025: art. 22: liability of the digital platform (read on 19/10/2026 in the sector report, not detailed today)
  • SAP Help, Managing Special Stocks (MM-IM), R/3 4.6C page: special stocks kept apart when they do not belong to the company or sit in a specific place

Proof delivered

Reconciliation of three balances (SAP, operator position, Block H) by cut-off date, with inventory adjustment scenarios.

04Special stock

Transfers between distribution centers and goods in transit

What weighs: The goods leave one DC and arrive days later, and each state treats the transfer in its own way.

What DFSpro changes: Transfer order with stock in transit, invoice and cost checked in both centers.

See the situation, the legal basis and the proof

The situation

Chains with several centers resupply each other in volume. Many goods are still in transit at month end.

Legal basis, line by line

  • LC 87/1996: art. 12, I (wording of LC 204/2023) and § 5: shipment to another establishment of the same owner and the option to treat the transfer as a taxed operation

Proof delivered

Report of open transit by invoice at the close, reconciled with the tax position of each state.

05Reverse logistics

Returns in volume: withdrawal, damage and blocked stock

What weighs: Each return has a deadline, a reason, a product condition and a destination, and each one changes the document and the stock.

What DFSpro changes: Return flow with the reason and the destination of the material linked to the invoice.

See the situation, the legal basis and the proof

The situation

E-commerce receives returns for withdrawal, defects and wrong delivery, with the product going back to stock, to repair or to disposal.

Legal basis, line by line

  • Consumer Code (Law 8,078/1990): art. 49: withdrawal within seven days on purchases made outside the store
  • Law 10,833/2003: art. 3, § 13: reversal of credit on goods that are unusable, damaged or destroyed
  • LC 214/2025: art. 379: CBS credit on goods received back from earlier sales, from 2027

Proof delivered

Scenario matrix with expected and obtained invoice, stock and credit, and a report of returns with no document.

06Credits

Credit balance and ST refund: credit left sitting in the wholesaler's cash

What weighs: Tax withheld on purchase and not used on sale leads to a refund with authorization and a deadline set by each state.

What DFSpro changes: Trail of the withheld tax by invoice and a refund report ready for the request.

See the situation, the legal basis and the proof

The situation

Wholesalers buy goods with ICMS-ST withheld and sell them to other states or to final consumers, and become entitled to a refund of what was withheld.

Legal basis, line by line

  • ICMS Agreement 142/2018, Confaz: clause 15: refund of the withheld tax, by a dedicated NF-e, with prior authorization and a 90-day term
  • Law 9,430/1996: art. 74: offsetting of credit against federal debits, for PIS and Cofins

Proof delivered

Report by item with purchase invoice, tax withheld and sale, reconciled with the bookkeeping.

07Unit of measure

Kits, boxes and units: the same item sold in different formats

What weighs: Bought by the box, stocked by the unit, sold as a kit. A wrong conversion distorts stock, cost, ST and the invoice.

What DFSpro changes: One conversion table and kit list per material, from the order to the EFD.

See the situation, the legal basis and the proof

The situation

The wholesaler buys by the box and pallet and sells by the unit and in promotional kits, and e-commerce builds temporary bundles.

Legal basis, line by line

  • EFD-ICMS/IPI Practical Guide, version 3.2.1 (updated 28/10/2025): record 0220: conversion factors between the commercial unit and the stock unit, from record 0200

Proof delivered

Report of materials with a missing or conflicting conversion, and inventory in each unit checked against record 0220.

08Stock

Loss, breakage and damage: reverse the credit without forgetting the inventory

What weighs: Goods that break, expire or disappear require a credit reversal and an inventory adjustment, and they almost never pass through the tax team.

What DFSpro changes: Reason for the stock write-off linked to the reversal rule and to Block H.

See the situation, the legal basis and the proof

The situation

At the scale of thousands of items, breakage and expiry are routine in a distribution center, with cycle counts and mass write-offs.

Legal basis, line by line

  • Law 10,833/2003: art. 3, § 13: reversal of credit on goods that are stolen, robbed, unusable, damaged or destroyed
  • LC 87/1996: art. 21, IV: the ICMS credited is reversed if the goods are lost, spoiled or disappear
  • EFD-ICMS/IPI Practical Guide, version 3.2.1 (updated 28/10/2025): H010 (inventory) and K280 (correction of an entry between two inventories)

Proof delivered

Report of write-offs by reason with expected and obtained credit reversal, and inventory reconciled with the bookkeeping.

09Reform

Opening stock at the switch to CBS: who was in the cumulative regime, ST or single-stage taxation

What weighs: The presumed credit on stock held on January 1, 2027 has conditions, and the stock must be proven item by item.

What DFSpro changes: Inventory of 31/12/2026 by item, with each item's classification made by the client.

See the situation, the legal basis and the proof

The situation

Wholesalers hold large and varied stock at the turn of 2026 to 2027, part under the cumulative regime, part with ST or single-stage taxation on purchase.

Legal basis, line by line

  • LC 214/2025: art. 381: cases, conditions and reference to an act of the Executive for checking the stock

Proof delivered

Cut-off inventory reconciled with K200 and Block H, with each item marked by case.

10Close

Close with millions of documents: reconcile, do not review invoice by invoice

What weighs: The daily volume of invoices and receipts makes the close depend on automatic reconciliation, and a difference of a few cents becomes a day of work.

What DFSpro changes: Reconciliation by exception: the system shows only what does not match.

See the situation, the legal basis and the proof

The situation

Sales platforms and wholesalers issue thousands of documents a day, with payment methods, returns and cancellations.

Legal basis, line by line

  • EFD-ICMS/IPI Practical Guide, version 3.2.1 (updated 28/10/2025): structure of the EFD-ICMS/IPI by blocks, including Block H and Block K

Proof delivered

Exception report by period with the cause for each document, and scenario regression before each rule change.

11Migration

From ECC to S/4HANA: fixed assets, CIAP in progress and credit balances

What weighs: An asset with installments still to be taken, credit balances and stock must reach the new system without losing their history.

What DFSpro changes: Load of assets and balances with line-by-line reconciliation, before and after go-live.

See the situation, the legal basis and the proof

The situation

Large operations migrate SAP and change the model for posting assets and tax documents.

Legal basis, line by line

  • LC 87/1996: art. 20, § 5: installments and cancellation in the 48th month
  • LC 214/2025: art. 380: depreciation installments and the monthly share continue as presumed CBS credit

Proof delivered

Balance reconciliation by asset and by area between source and target, and a report of installments to take in the first close.

12Accounting and tax

Online sale to another state: DIFAL for the final consumer

What weighs: Each order to a final consumer in another state requires the calculation, payment and tax reporting of the rate difference, in high volume and with state-specific rules.

What DFSpro changes: DIFAL rule by destination state in the invoice calculation and reconciliation in the tax calculation.

See the situation, the legal basis and the proof

The situation

Online stores and wholesalers selling directly to individuals ship across the country. The sender becomes the taxpayer for the rate difference owed to the destination state, and the order may start and be delivered in different states.

Legal basis, line by line

  • LC 190/2022, arts. 1 and 3 (Planalto): art. 4, § 2, II, and art. 11, V, b, and § 7 of LC 87; effect under art. 150, III, c, of the Constitution
  • STF, Topic 1093 of general repercussion: title on the need for a complementary law for DIFAL; final judgment on 30/03/2022. Literal thesis not read

Proof delivered

Scenario matrix with expected and obtained values by state, and reconciliation between invoices, tax calculation and payment slips for the period.

13Credits

ICMS-ST outside the PIS and Cofins base of the substituted wholesaler

What weighs: A wholesaler that buys with ICMS-ST included must separate that amount from revenue in the contributions base, invoice by invoice, and follow the time limit.

What DFSpro changes: ICMS-ST portion identified by item and treated in the PIS and Cofins base by the client's criterion.

See the situation, the legal basis and the proof

The situation

Wholesalers of goods under tax substitution resell products whose price already carries the tax withheld on purchase. The PIS and Cofins calculation needs to know how much of that amount went into revenue.

Legal basis, line by line

  • STJ, Repetitive Topic 1125: thesis set by the First Section, final judgment and modulation with a milestone on 15/03/2017
  • STF, Topic 69 of general repercussion: ICMS in the PIS and Cofins base, final judgment on 09/09/2021. Literal thesis not read

Proof delivered

Calculation record by period with the ICMS-ST portion isolated, reconciled with the base booked.

14Special stock

Transfers between distribution centers and keeping the credit

What weighs: A shipment to another establishment of the same owner does not create tax, but the credit from earlier operations must follow along, by establishment and by state.

What DFSpro changes: Transfer with no taxable event, with the credit rule and the option to tax handled in the master data.

See the situation, the legal basis and the proof

The situation

Distribution networks move goods between DCs in different states to supply online sales and wholesale. For years the treatment changed by state, with disputes over incidence and over credit.

Legal basis, line by line

  • LC 204/2023, arts. 1 and 3 (Planalto): new art. 12, § 4, of LC 87 (non-incidence and keeping of the credit); § 5 by promulgation of the vetoed part; in force on 01/01/2024

Proof delivered

Transfer scenarios with expected and obtained CFOP, taxation and credit, and credit reconciliation by establishment.

15Reform

Sale through a digital platform: who is liable for IBS and CBS

What weighs: A seller using a marketplace comes to depend on a registered tax document and on information that the platform provides, and bad data creates joint liability.

What DFSpro changes: Marketplace operation tied to the electronic document and to reconciliation with the payout.

See the situation, the legal basis and the proof

The situation

E-commerce sellers issue invoices, and part of the sales go through platforms that charge, pay out and report the operations. With the reform, the platform joins the chain of liability.

Legal basis, line by line

  • LC 214/2025, art. 22 (Planalto, with the wording of LC 227): liability of the digital platform, cases and information required; wording given by LC 227/2026

Proof delivered

Reconciliation of sale, electronic invoice, platform payout and tax calculated, by order and by period.

16Credits

Freight and storage on a sale: PIS and Cofins credit when the seller bears the cost

What weighs: Freight and storage on a sales operation create credit only when the seller bears the cost, and the cost arrives in CT-e, service invoices and an allocation per order.

What DFSpro changes: Freight and storage cost on a sale identified by order and by who bears the cost.

See the situation, the legal basis and the proof

The situation

Wholesale and e-commerce deliver with their own or hired freight and store with operators. The cost spreads across many documents and orders, with part paid by the customer.

Legal basis, line by line

  • Law 10,833/2003, art. 3, IX (Planalto): credit on storage of goods and freight on a sale, in the cases of items I and II, when the seller bears the cost

Proof delivered

List of order, CT-e, cost and who bears it, reconciled with the credit base booked.

The tax position in each situation is the client's decision. DFSpro designs the behavior in SAP, configures it and proves it with scenarios, so the client's decision runs the same way on every document. Where to start: the SAP Tax Diagnostic.

Request the SAP Tax Diagnostic
How DFSpro comes in

Diagnostic, project and AMS Fiscal

Diagnostic

We measure the environment: item master data, ST and DIFAL rules, transfers, returns and the tax calculation. The result is a list of differences with evidence. Learn more in tax diagnostic in SAP.

Project

We design and configure the tax layer, including the move to IBS and CBS, and prove the behavior in testing. See migration to S/4HANA.

AMS Fiscal and GUEPARDO Tax

Ongoing support in AMS Fiscal. GUEPARDO Tax is a product of NTT DATA, and reaches the client through the Authorized Channel: DFSpro deploys it and sells the license.

The limit of our role

Our role is to design, configure and prove the system's behavior in the client's environment. The tax decision belongs to the client: the position on each product, whether or not to tax the transfer, and how to answer the state tax authority.

Official sources

Rules and rulings, checked on 19/10/2026

All the pages below were opened on the date shown. The status of each rule may change after that date.

Confaz

Federal legislation

Frequently asked questions

Questions from the tax director of wholesale and e-commerce

01Is the wholesaler always the one responsible for ST on an interstate sale?+

No. ICMS Agreement 142/18, clause 8, says the sender may be responsible, for goods covered by an agreement or protocol that sets up the regime. The provision for each product and state must be checked in the matching act.

02Does ST apply when we transfer goods from one distribution center to another?+

Clause 9 of Agreement 142/18 removes the regime on transfers between establishments of the sender, except when the recipient is a retailer. Since 2024, LC 204/23 also removes the ICMS taxable event on those transfers.

03Is the taxpayer required to stop taxing the transfer?+

Under LC 204/23, the rule is non-incidence, with the credit kept. Art. 12, § 5, of LC 87/96 lets the taxpayer choose to tax it. Form and deadline for the choice: not checked. The choice is the client's.

04Who pays DIFAL on a sale from the website to another state?+

When the buyer is not a taxpayer, the sender pays the destination state the difference between the internal rate and the interstate rate, by GNRE or state payment slip, at shipment and per operation (ICMS Agreement 236/21).

05What changed in the DIFAL split between origin and destination?+

EC 87/15 created the split in stages, from 20% to the destination in 2015 up to 80% in 2018. Since 2019 the difference is 100% for the destination state, under art. 99 of the ADCT.

06Does the poverty fund surcharge go into DIFAL?+

Agreement 236/21, clause 2, § 4, says the surcharge of up to two percentage points is part of the calculation, with payment under the legislation of the destination state.

07Does the marketplace pay the tax on my supplier's sale?+

It may be liable for IBS and CBS together with the supplier, in the cases in art. 22 of LC 214/25. It is not liable for the differences if it provides the information and does the split payment when available (§ 7). The ICMS rule before the Reform: not checked.

08Who is a digital platform under LC 214/25?+

One that acts as an intermediary in a remote or electronic operation and controls billing, payment, terms and conditions, or delivery. A party that only provides an authorized payment service or only advertises is not a platform.

09How does a return of an online purchase work?+

The Consumer Code gives 7 days to withdraw from a purchase made outside the store, with the amounts refunded right away. For IBS and CBS, the return uses the base and rate of the original operation (LC 214/25, arts. 12 and 17).

10Can a return NF-e refer to an NFC-e?+

SINIEF Adjustment 07/05, clause 3, § 9, bars, effective 14/12/2026, an outbound NF-e that refers to an NFC-e, except the complementary one. The procedure for returning a sale made with an NFC-e: not checked.

11What changes in 2026 with IBS and CBS?+

In 2026, a taxpayer that is up to date with the ancillary obligations set by law does not have to pay IBS or CBS (LC 214, art. 348, § 1). Paragraph 2 keeps PIS and Cofins payable in full, and item III, letter c, leaves Simples Nacional taxpayers out of the test rates. Anyone who pays IBS and CBS offsets against PIS and Cofins or, with no debit, against another federal tax or gets a refund within 60 days. If there is an infraction notice for an ancillary obligation, § 3 gives 60 days to fix the omission.

12Does split payment already apply to anyone selling online?+

LC 214/25 defines split payment in arts. 31 to 35, with a gradual rollout. Regulation and calendar: not checked. See split payment in SAP.

13Does my state ICMS wholesale incentive end?+

LC 160/17, as worded by LC 186/21, allows the benefit to be used until December 31 of the fifteenth year after the agreement takes effect, for a commercial-activity benefit where the beneficiary is the actual sender, with a 20% yearly reduction from the twelfth year (art. 3, §§ 2 and 2-A), a reduction that ADCT art. 128, § 2, removes from 2029 to 2032. ICMS ends in 2033 (ADCT, art. 129). The term of your benefit depends on the grant act and on the agreement of each state: not checked.

14Is an ICMS benefit valid without registration with Confaz?+

No. Art. 3 of LC 160/17 requires the list of acts, and the registration and filing of the documents with Confaz, published on the National Tax Transparency Portal. Without this, § 1 requires the grant acts to be revoked. ICMS Agreement 190/17 repeats the conditions. Which states registered what: not checked.

15Does the Reform make up for the end of my ICMS benefit?+

In part and with conditions. Art. 384 of LC 214/25 provides compensation from 2029 to 2032 through a fund, for onerous benefits granted in due form up to 31/05/2023, with a term up to 31/12/2032 and the conditions of the act met. Sole paragraph, III, leaves out the benefits of § 2-A of art. 3 of LC 160. The request is reviewed by the Federal Revenue Service (art. 386). How your case is classified is the client's decision.

16Does a Simples wholesaler pay ST outside the single payment?+

Art. 13, § 1, XIII, of LC 123/06 says the single payment does not include the ICMS due on operations under ST, single-stage taxation and advance payment that ends the taxation, on the product lists in the text, governed by the legislation for other companies. How it applies to your product and your operation: not checked, with the decision left to the client and its legal team.

17Does DFSpro decide whether my company should choose to tax the transfer?+

No. The tax decision is the client's. DFSpro designs and proves the system's behavior under both options, with evidence, so the company and its legal team can decide.

Next steps

Bring your map of destination states and your channels for online sales

Tell us how your operation works: states, distribution centers, platforms and the tax point that bothers you most. The scope comes out of that conversation, with no fixed deadline.

Talk to DFSpro about your sectorTake the readiness test (2 minutes)

To go deeper first: electronic tax documents in SAP and ICMS-ST and DIFAL in SAP.