By Mariana Brambilla Bertasso and Gabriela Marugal Munhoz Rodrigues
Technical Note No. 005, dated November 19, 2025, published by the Executive Secretariat of the Managing Committee of the National Standard Electronic Service Invoice (SE/CGNFS-e), created a specific group for the leasing of movable assets and transactions involving real estate within the Service Provision Declaration (DPS) of the NFS-e.
The new fields and information groups that will be included in the NFS-e layout in the Production and Restricted Production (testing/homologation) environments starting in January 2026 are those published in Technical Note No. 004, dated August 19, 2025. The updates provided in Technical Note No. 005 will be made available in these environments at a future date to be announced on the NFS-e Portal.
Within the DPS, the IBSCBS group (path: NFSe/infNFSe/DPS/infDPS/) has been created, which will contain all subgroups and information related to the new taxes introduced by the Consumption Tax Reform.
Technical Note No. 005 established specific fields for donation and leasing operations involving movable assets, in which the NCM Code of the movable asset, its description, and quantity must be reported.
Additionally, the leasing of movable assets may be formalized regardless of the municipality’s status of adherence or the taxpayer’s option to use national public issuers.
Within the same “IBSCBS” group, an Information Group for Transactions Related to Real Estate, except Construction Works, was created. This field will be labeled “imovel.” This group must include information regarding the Property Tax Registration Number (related to IPTU collection), the Brazilian Real Estate Registry Code (CIB), and the detailed address of the property.
The newly created service code will include information related to transactions involving real estate, including Consideration-Based Assignment of Real Estate, Real Estate Leasing, Easement, Assignment of Use or Space of Real Estate, and Permission of Use or Right of Way of Real Estate—provided that these last categories do not constitute taxable operations under the ISSQN.
It is important to note that service items classified under “99” do not provide for ISS to be highlighted on the fiscal document, covering only IBS and CBS. Furthermore, for services categorized under subitem “99.03,” the NBS code to be reported must be “1.1002.10.00” when the property is residential, or “1.1002.20.00” when it is non-residential.
Fields have also been created for reporting the gross amount of the transactions, as well as information relating to deduction amounts and the reduction of the IBS and CBS tax bases, applicable to the specific regime for transactions involving real estate. In addition, fields have been included for IBS/CBS credit reversals and for referencing the NFS-e relating to advance payment for offsetting purposes.
The new fields and information groups do not yet have a defined date for release in the Production and Restricted Production (testing/homologation) environments. However, it is important for companies engaging in these transactions to begin adapting to these new models.
The Tax Law Team at Marins Bertoldi Advogados remains available to assist clients in performing proper evaluations and the necessary procedures for tax compliance.
