--- title: "Tax Reform: What Changed in the Constitution with Amendment 132/2023 | VMAHUB" description: "EC 132/2023: what changed in the Constitution with the tax reform. Affected articles and legal foundations for tax lawyers." canonical: "https://vmahub.com/en/blog/emenda-constitucional-132/" language: "en" source: "VMAHUB" --- - \[Home\](https://vmahub.com/en/) - \[Blog\](https://vmahub.com/en/blog) - Tax Reform: What Changed in the Constitution with Amendment 132/2023 Reform Fundamentals # Tax Reform: What Changed in the Constitution with Amendment 132/2023 EC 132/2023: what changed in the Constitution with the tax reform. Affected articles and legal foundations for tax lawyers. **Last reviewed:** August 13, 2026 ![Tax Reform: What Changed in the Constitution with Amendment 132/2023](https://vmahub.com/assets/img/posts/blog/emenda-constitucional-132.webp) ## Executive Summary Constitutional Amendment 132/2023 created the constitutional basis for the consumption tax reform. It did not, on its own, resolve the entire operation of the new system, but it defined the pillars that enable the transition to CBS, IBS and the Selective Tax. ## Why a Constitutional Amendment Was Necessary ICMS, ISS, PIS and COFINS are not merely operational taxes. They have their own constitutional basis. For that reason, the reform required a change to the Constitution before being detailed by complementary law. Without EC 132/2025: - there would be no basis for the new dual VAT; - the redistribution among federative entities would lack support; - the transition would lose legal certainty. ## What EC 132 Did In practical terms, the amendment: - paved the way for replacing the old taxes with a new consumption structure; - reinforced the logic of non-cumulativity; - consolidated the destination principle as the axis of revenue collection; - allowed differentiated treatment for specific sectors provided for in the reform. It is not the operational manual of the system. It is its constitutional foundation. ## Why This Matters to the Tax Lawyer For the tax lawyer, EC 132 is important because it defines the limit of what the complementary law may or may not do. Every future discussion about credit, sector exceptions, administrative simplification or federative competence comes back to this text. The most relevant questions become: - does the regulation respect the constitutional framework? - is the right to credit being preserved in a coherent manner? - is the sector-specific treatment aligned with what the Constitution authorized? ## Questions That Remain Open Even with the amendment, there remain themes that depend on regulation and interpretive dispute: - the extent of the right to credit; - the limits of sector exceptions; - the balance between simplification and ancillary obligations; - judicialization of the transition. In other words: EC 132 closed the political phase of creating the constitutional basis, but it did not close the legal phase of interpretation. ## What to Do in Practice - Read EC 132 as an interpretive milestone , not just as a historical fact. - Compare the infraconstitutional regulation with the constitutional authorization . - Monitor credit and competence theses that may generate relevant disputes. - Avoid advice based solely on operational rules , without a constitutional reading of the matter. Want to understand how Amendment 132 directly impacts your company’s tax strategy? At /en/napratica, VMAHUB publishes technical analyses for tax law professionals. For a consultation on how the reform affects your firm or company, talk to our team: **\[contato@vmacompliance.com.br\](mailto:contato@vmacompliance.com.br)** **Read also:** - \[Tax Reform 2026: Complete Guide\](https://vmahub.com/en/blog/reforma-tributaria-2026) - \[CBS: What It Is and How It Replaces PIS/COFINS\](https://vmahub.com/en/blog/cbs-reforma-tributaria) - \[IBS: What It Is and How It Replaces ICMS and ISS\](https://vmahub.com/en/blog/ibs-imposto-sobre-bens-e-servicos) ## Want to apply this content to your own reality? If the topic “Tax Reform: What Changed in the Constitution with Amendment 132/2023” raised a practical question, send us your context. The VMAHUB team will get back to you with the best next step. ### Choose the most suitable channel to start the conversation. 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