The fiscal war shaped logistics in Brazil over the past decades. I watched entire companies move their distribution centers from São Paulo to Espírito Santo, from Minas to Santa Catarina, just to capture an ICMS benefit. I saw tiny city halls lure the headquarters of giant tech companies by offering ISS at 2%. Brazil got used to running businesses not by the logic of efficiency, but by the logic of tax manipulation.
That is going to end. CGIBS Resolution No. 6/2026 decrees the end of this era by transferring ownership of the tax from the origin to the destination of consumption.
I have always argued that businesses should be built on real value, not on tax workarounds. Article 12 of the resolution is a bucket of cold water on anyone still betting on the past. The tax stops belonging to the state or municipality where the company is headquartered and starts belonging to the place where the good or service is actually delivered, made available or consumed.
For physical goods, the rule is simple: the place of the operation is where the product is delivered to the recipient. But the big impact is in the digital and services world. For streaming services, SaaS, apps and digital platforms, the tax goes to the buyer’s main domicile.
What does that mean in practice? It means it no longer matters whether your tax headquarters sits in an ISS haven. If your client is in São Paulo, the tax goes to São Paulo. If they are in the interior of Bahia, it goes to the interior of Bahia. Geolocation, the billing address, the user’s IP or the national registry data become the tax authority’s compass to determine where the money goes.
This change directly affects the heart of digital companies, fintechs and marketplaces. Logistics distribution will once again be planned around proximity to the customer and the efficiency of the transport network, and no longer around the bargaining table of state tax benefits.
But there are gray areas that still worry me. The resolution creates complex rules to define the destination in specific situations. For example, in passenger transport services, the place is where the trip begins; but in cargo transport, it is where the cargo is delivered. That duality is already starting to muddy the waters.
What is still not entirely clear is how location conflicts will be resolved in purely digital operations, especially when the customer uses VPNs or has multiple billing addresses. On top of that, oversight of international digital operations will be a rather interesting challenge for the new Managing Committee. And for small companies, the operational complexity of handling multiple tax destinations, even with a unified system, will demand a management maturity that many still do not have.
The fiscal war as we knew it is dead. Whoever focuses on serving the customer better, wherever they are, will ride this wave. Business intelligence returns to the place it should never have left: the real operation.
