Split payment will anticipate the transfer of taxes to the government

One of the government’s bets to help implement and combat tax evasion is the split payment. Unknown to the general public, the technological resource is being developed by the Federal Revenue Service in partnership with other institutions and should debut in January 2026.

The term in English can be translated as “split payment”. But this is not an installment payment for the purchase. What will happen is that, at the moment the product or service is paid for by the consumer, the system will already separate the value that is due to the seller and the tax amount – and this will be immediately forwarded, in the appropriate proportions, to the federal governments , state and municipal.

This way, tax collection is advanced. Today, taxes are collected after sales are completed, companies keep accounts of everything that was sold and deduct credits from the production chain and only then pay their taxes the following month.

Experts consulted by People’s Gazette assess that the split payment It can help with tax collection, in addition to being important for the implementation of tax reform, in order to provide more transparency for consumers and avoid mistrust between federal entities. However, they also state that the tool can have negative impacts, especially for small and medium-sized businesses.

Still in the development phase by Federal Revenue technicians, the split payment It can only be used in transactions made by digital means, such as bank slip, pix, automatic debit or credit card.

O split payment changes the way taxes are collected, by dividing the payment amount between the recipient and the Tax Authorities at the time of the transaction, says Cassius Leal, founder and CEO of Advys Contabilidade.

“This model aims to combat tax evasion, since, with direct payment by the government at the time of payment, the possibility of tax default is reduced. Furthermore, this method brings transparency, as it eliminates the need for intermediary companies to withhold and transfer taxes later, as currently occurs”, he states.

The executive director of the Independent Fiscal Institution (IFI), Marcus Pestana, states that the split payment It also brings gains in transparency for the taxpayer who, at the time of purchase, will be clear about how much they are paying. “We will know in each consumption operation how much tax we are paying. Today it comes built-in, you don’t really know what’s inside,” he says.

Furthermore, Pestana assesses that the system avoids distrust among federal entities in relation to the Union when transferring taxes, which will be especially useful during the implementation of tax reform. Throughout Brazilian history, he describes that there were a series of centralizing and decentralizing movements in tax collection, which generated distrust among federated entities.

“And then there is this centralization-decentralization pendulum that is characteristic of Brazil’s history in tax terms. So, it is extremely necessary, including to harmonize the three levels of government, so that there is no suspicion that all the money was not transferred. So, the more automatic it is, the better”, he adds.

When changing collection logic, split payment can affect small businesses

According to the doctor and master in Tax Law from PUC-SP and president of the Tax and Constitutional Law Commission of the OAB-SP, André Félix Ricotta de Oliveira, the split payment It will change the tax collection system in the country.

“Every payment that a company or customer makes through a financial institution, whether via bank slip or credit or debit card, the financial system will already make the division. What belongs to the seller and what is owed to the Union, states and municipalities, IBS and CBS. In this way, the entire system of taxes that apply to consumption changes,” he stated.

The tax expert states that many companies, due to the credits that end up discounting the recurrence of taxes throughout the production chain, do not even pay these taxes. Others, due to cash flow, may also choose to delay paying taxes and incur a fine, directing resources to pay suppliers, for example, which can no longer occur in cases of digital payments.

Juliana Vaz, tax lawyer at VBSO Advogados, explains that one of the concerns regarding the adoption of this system lies precisely in the impact on companies’ cash flow, as the amount related to taxes will be immediately allocated to the tax authorities. In the current model, the company can manage resources until their due date.

“This will require companies to be more rigorous in adapting to the new model, meeting their financial commitments and maintaining their stability, which can represent a major challenge for small and medium-sized companies”, he states.

Therefore, the system brings substantial challenges to small and medium-sized companies, which have difficulty dealing with the high tax burden and bureaucratic complexity in Brazil.

“Adding a new automatic tax collection system, without providing adequate support, could compromise the functioning of these companies, especially those that do not have the technological structure or accounting team to deal with this innovation”, says Cassius Leal, from Advys Contabilidade.

He assesses that, by requiring robust technological systems to guarantee the correct execution of payment splitting, the split payment This may result in the need to invest in updating systems and training teams to ensure compliance with the new rule. It will be an additional expense for companies.

Time is the government’s biggest challenge in developing the split payment

The refund and financing to make these adjustments by the private sector is one of the concerns of the financial system regarding the implementation of the split payment, as assessed by Juliana Vaz, from VBSO Advogados.

In the government’s view, however, one of the biggest challenges is time. Marcus Pestana, from IFI, mentions that the extraordinary secretary of Tax Reform, Bernard Appy, highlighted that time is the main challenge when it comes to split payment.

Expectations are that tax reform regulatory proposals will be approved later this year. This way, the government would start testing the split payment in January 2026.

According to Pestana, Appy would have stated that the challenge is difficult, but completely viable. “Whoever is working, with their hands dirty, is optimistic. And today technology allows everything, with artificial intelligence, it’s no big deal”, says the executive director of IFI.

In June, in a panel on the split payment During the XVII National Meeting of Tax Administrators (Enat), the manager of Serpro and national manager of the Brazilian Tax Reform Strategic Project, Robson Dias Lima, stated that the government has the knowledge to develop the system.

“My role here today is to tell you this: despite all the complexity and changes in relation to the current model, the split payment Yes, it is technically viable. Don’t worry about technology, because technology can handle it”, he guaranteed.

System will need to account for credits and transition of taxation from origin to place of consumption

Another point is the adequacy of the split payment to the production credit system. Currently, the tax system allows taxes charged, for example, in the metallurgical industry to manufacture automotive parts, not to be double charged on the final assembly of cars. Thus, automakers deduct these credits from their taxes.

According to André Félix, the tax reform team raised the possibility of returning the credits to the industry at a later stage. However, the idea was not well accepted and, given the impasse, the system is being developed to account for credits immediately.

“The financial system will already see if I have credits and high technology will already make this crossing at the time of sale. If I don’t have credit, pay the tax; If I have credit, I just deduct the tax, excluding credits”, he explained.

The transition of the allocation of taxes, from the place of origin of production to the place of consumption, is another aspect of the reform that must be considered by the split payment. According to Marcus Pestana, this transition will take 50 years, discounting and transferring small percentages of revenue from one location to another.

The IFI’s executive director states that this long transition period is necessary, as, if it were carried out more quickly, it could generate very sudden losses for municipalities and states of origin. The algorithm, however, will have to reflect this gradual transfer.

“Today, thanks to the advancement of information technology, of all the tools we have, it is completely viable. The Federal, state and municipal revenue teams are working together, they are working together, across the three levels of government”, he states.

European studies concluded that adoption of split payment did not cover development and implementation costs

With the tool still being developed, the government did not detail its costs. THE People’s Gazette sent questions to the Federal Revenue Service and Serpro regarding the system, but received no response until the publication of this report. The space remains open to demonstrations.

According to André Felix, in the European Union studies showed that the revenue gains generated by split payment with combating fraud and default were not significant compared to their implementation costs.

“They tried to implement it in the European Union and it didn’t work, because the cost of implementing it would be greater than the tax evasion avoided. And it could also bring harm to the management of companies”, he commented.

Likewise, Cassius Leal assesses that the implementation of split payment requires significant investment in technology, both by government and companies. Furthermore, system maintenance requires continuous monitoring and technological updating, which generates operational costs.

“On the other hand, the expected gains for the Federal Revenue Service can be significant. The reduction of fraud and tax evasion, combined with direct and continuous collection, can offset implementation costs in the medium to long term. However, it is crucial that the government publishes detailed studies on the costs and benefits of this proposal in the Brazilian context, since the tax scenario here is different from that of other nations”, he says.