One of the biggest innovations foreseen by the Tax Reform, split payment should only come into operation from 2027. The fractional payment of taxes 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). The delay in preparations between companies and the financial sector led the government to postpone the entry into operation of the new system.
The mechanism causes the amount of taxes to be automatically separated at the time of payment of the commercial transaction. 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 lawyer Franciny de Barros, partner in the tax area at Candido Martins Cukier, due to the information of unpreparedness coming from financial and technological systems companies, it was already expected that the split payment tests would be postponed from 2026 to 2027 by the Revenue.
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“On the one hand, this spacing helps with the preparation and literacy of taxpayers, on the other hand, it tends to postpone plans to implement the Tax Reform, an audacious plan that demands strong preparation,” said Franciny.
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For the lawyer, the model also imposes significant impacts on companies’ cash flow, because it requires a robust technological infrastructure to process millions of transactions instantly.
Franciny remembers that 2027 will be a year of testing. “It will be like changing a tire while the 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.
Real time
“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 specialized 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.”
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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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Cash adjustment
The most immediate impact, according to Franciny, 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.”
