TITLE:
Designing Excise Taxation: A Functional Comparison between China and Brazil after the 2023 Brazilian Tax Reform
AUTHORS:
Hadassah Laís Sousa Santana
KEYWORDS:
Excise Taxation, Selective Consumption Tax, Externalities, Institutional Design, Tax Reform, China, Brazil
JOURNAL NAME:
Beijing Law Review,
Vol.17 No.3,
September
14,
2026
ABSTRACT: This article develops a comparative legal-institutional analysis of excise taxation on consumption in China and Brazil, examining how two large emerging economies operationalize the functional principles of excise taxation under distinct institutional conditions. Following the 2023 Brazilian tax reform, which created the Selective Tax (IS) through Constitutional Amendment 132/2023 and Complementary Law 214/2025, a productive comparison emerges with China’s Consumption Tax (消费税), in operation since 1994. The analysis is organized around an analytical matrix of five interdependent design dimensions, namely selectivity, proportionality, enforcement capacity, fiscal coordination, and distributive sensitivity. The central argument is that China and Brazil should be understood not as competing models, but as distinct institutional adaptations of common functional principles. Three substantive conclusions emerge from the analysis. No model of excise taxation is universally superior. The prospective advance of the instrument in both jurisdictions depends on complementing taxation by category with taxation by attribute. The South-South dialogue between the two systems also holds analytical and public-policy value.