understand the system that will change the way you pay taxes in Brazil

Of all the innovations that will come with , from 2026 onwards, one of them is already emerging as a favorite to become one of the most transformative – and also challenging – for Brazilian companies. The split payment, or fractional payment, will radically change the way of collecting the new taxes on consumption created by Complementary Law No. 214/2025, the Tax on Goods and Services (IBS) and the Contribution on Goods and Services (CBS).

In practice, the mechanism means that the amount of taxes is automatically separated when the commercial transaction is paid. In other words, when the consumer pays for a product or service, the financial institution already divides the amount into two parts: one goes directly to the public coffers, the Federal Revenue Service and the IBS Management Committee, and the rest is passed on to the supplier.

With this, the government intends to reduce tax evasion, default and fraud, in addition to ensuring immediate and transparent tax collection. But, according to experts interviewed by the InfoMoney, the model also imposes significant impacts on companies’ cash flow and requires a robust technological infrastructure to process millions of transactions on the spot.

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Real-time tax

“Split payment changes the logic of collection because instead of being declared later, it starts to be collected at the moment of the transaction, inaugurating the concept of tax in real time”, explains Paulo Zirnberger de Castro, CEO of Omnitax, a technology company specializing in tax management solutions.

For the expert, this is already one of the most disruptive changes in Brazilian fiscal history, creating an automatic tax collection system. According to him, integration will be done through interfaces, or APIs, between banks, tax authorities and company systems. “The value is automatically divided: one part goes to the supplier, the other to the government. This makes collection more secure, but requires cutting-edge technology and integrated fiscal governance.”

The legislation provides for three models:

a) Simplified Split – aimed at operations with end consumers, with a pre-defined rate;

b) Split with Credit Management – which recognizes accumulated tax credits and adjusts the net amount automatically;

c) Smart Split – the most advanced, which will validate debits and credits in real time across the entire supply chain.

Technological challenges

For tax lawyer Francine de Barros, partner at Candido Martins Cukier Advogados, the system brings benefits mainly in terms of transparency, but creates several immediate challenges for companies and financial institutions.

“The bank will be responsible for separating the tax amount and passing it on to the public coffers, leaving the taxpayer with only the net amount. This has a profound impact on the cash flow of companies, which lose control over when to collect taxes”, he explains.

Therefore, she highlights that technology will be the critical point of the entire transition. “Split payment requires strong integration with banks, the Federal Revenue Service and the IBS Management Committee. And any failure on the platform can cause payments to stop, cause delays and even losses. And, in the beginning, no one – not even the government – ​​is fully prepared for this”, says the expert.

Francine remembers that 2026 will be a year of testing. “It will be like changing a tire while a car is running. Companies and Revenue will learn together. The final model is bold and promising, but the path to get there will be a lot of adjustment. But it tends to be as easy as the individual’s pre-filled income tax declaration”, he compares.

A model that comes from outside

Tax expert Caio Ruotolo, partner at Silveira Advogados, explains that split payment is not a “Brazilian invention”. The model is already applied in European and Asian countries and even in Chile, which inspired the creation of the electronic invoice.

“The system is effective against cold invoices and chain fraud, as the tax is segregated at the time of payment. Furthermore, the taxpayer is now entitled to automatic refunds, as the tax authorities cannot claim a lack of resources to return tax credits”, he explains.

Ruotolo states that, at the same time as it reduces gaps for evasion, the model requires real-time control of companies’ credits, which will now be directly monitored by the Revenue. “The idea is that taxpayers only need to buy and sell with a note. Simplification is the ultimate goal, but there is still a long way to go,” he states.

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Costs and risks

According to Morvan Meirelles Costa Junior, tax lawyer and partner at Meirelles Costa Advogados, the new way of paying taxes also imposes new responsibilities on banks and payment platforms, which will have to automatically collect taxes.

“These payment processors will need to invest heavily in technology, because they assume unprecedented fiscal responsibility, since the law even provides for joint and several liability in some cases,” he said.

For Costa Junior, the biggest risks lie in the complexity of the transaction, with the harmonization between the systems of the federative entities. “Any mismatch between the Union, States and Municipalities can generate bottlenecks and inconsistencies. And this can end up making payment services more expensive.”

Cash adjustment and preparation

The most immediate impact, according to Francine, will be on the companies’ cash flow. “As the payment occurs immediately, the taxpayer loses the financial breath he previously had until the tax is due. This can compromise liquidity, especially in sectors with lower margins”, he explains.

She recommends that companies anticipate, simulating impact scenarios and preparing their teams. “It is essential to review ERP systems, financial reconciliation and tax credit management. Preparation also involves personnel and this is what will differentiate those who suffer from those who adapt.”

What remains to be defined

Despite the guidelines already established by Complementary Law No. 214/2025, several points depend on regulation. Among them, the tax rate parameters, the functioning of electronic platforms and the rules for automatic credit compensation, according to Francine de Barros.

“Today, both the private sector and the government itself are not yet ready to operate the system in its full form. The transition must be done jointly with the Revenue, Management Committee, banks and companies. And the first year will serve much more as a period of testing than of effective collection”, he states.

Meanwhile, companies are already advised to simulate impacts and plan financial and technological adjustments.