Split Payment in the Tax Reform: financial and strategic impacts for Brazilian companies

Brazil's Tax Reform has ushered in one of the most profound transformations of the business environment in recent decades. With the enactment of Constitutional Amendment No. 132/2023 and the regulations brought by Complementary Law No. 214/2025, companies of all sizes now face a new landscape of fiscal, operational, and financial adaptation.

Among the main changes, split payment stands out as one of the most relevant mechanisms and, at the same time, one of the most challenging for the productive sector. Although the model has been presented as a solution to increase tax collection efficiency, reduce tax evasion, and simplify tax payment, its implementation raises important concerns about cash flow, working capital, business liquidity, and technological infrastructure.

For business owners and managers, the discussion goes beyond tax matters. Split payment directly impacts companies' financial dynamics, requiring process reviews, system restructuring, and new tax governance strategies.

What split payment is and why it matters to companies

Split payment, or divided payment, is a collection model in which the amount corresponding to taxes levied on a given commercial transaction is segregated at the moment the financial settlement of the transaction occurs.

In practice, this means that when making a sale, the company will not receive the full gross amount of the transaction. The portion corresponding to the IBS (Tax on Goods and Services) and the CBS (Contribution on Goods and Services) will be automatically directed to the tax authorities, while the supplier will receive only the net value of the transaction.

This model represents a structural change compared to the current system. Today, companies receive the full amount of the sale, manage their financial resources, and pay taxes later, according to the assessment period.

With split payment, this logic changes substantially. The tax no longer passes through the company's cash flow. This significantly alters the financial management of organizations.

The proposal was incorporated into the Tax Reform as an instrument to strengthen tax collection and reduce tax delinquency. The logic is simple: if the tax is collected at the moment of payment, the risk of evasion is reduced and the predictability of state tax revenue increases.

From a fiscal perspective, the model may bring significant gains. From a business perspective, however, the impacts require strategic attention.

The impact on cash flow and working capital

The main concern for companies lies in the direct effect of split payment on cash flow.

In most business operations, cash management is one of the pillars of financial sustainability. Resources that enter the company are used to pay suppliers, payroll, investments, operational expansion, and the maintenance of working capital.

In the current model, even considering the future obligation to pay taxes, there is a financial window between the receipt of revenue and the payment of the tax. This dynamic allows for greater management flexibility.

With split payment, this margin practically disappears.

By immediately withholding the tax portion of the transaction, the company begins to operate with less available liquidity. This can especially affect sectors with reduced margins, high operational recurrence, or strong dependence on working capital.

Retail, industry, logistics, large-scale services, and marketplace operations tend to feel more intense impacts.

For small and medium-sized companies, the concern may be even greater. Businesses that already operate with tighter cash flow may face a greater need for capitalization, financial renegotiation, or reorganization of internal processes.

In practice, split payment requires more rigorous and predictive financial management.

Operational and technological challenges

Beyond the financial impact, the implementation of split payment brings significant operational challenges.

The new system depends on a high level of integration between companies, financial institutions, payment systems, the Federal Revenue Service, and the IBS Management Committee (Comitê Gestor do IBS).

This means companies will need to review their internal billing systems, tax compliance, financial reconciliation, and tax data management.

ERP systems, payment platforms, tax management software, and accounting routines will need to operate with greater synchronization and real-time processing capacity.

Technological adaptation is no longer a competitive advantage but has become an operational necessity.

Companies with low digital maturity may face greater difficulties during the transition.

In addition, any systemic failures, inconsistencies in tax data, or delays in refunds can have significant effects on companies' financial routines.

This scenario reinforces the need for advance planning.

Legal certainty and regulatory risks

Although the Tax Reform promises to simplify the system, the transition period will inevitably produce interpretive doubts and regulatory challenges.

The implementation of the IBS and CBS will occur gradually between 2026 and 2033. During this period, companies will need to deal with old and new systems simultaneously.

This hybrid environment tends to increase compliance risks, operational errors, and administrative costs.

Another sensitive point involves the refund of tax credits.

In the non-cumulative model, the efficiency of the system depends directly on the speed and predictability of offsetting or refunding accumulated credits.

If refund mechanisms do not operate promptly, companies may face significant financial imbalances.

This concern is especially relevant for businesses with long production chains, a large volume of inputs, or a high generation of tax credits.

The challenge, therefore, is not only to collect taxes more efficiently, but to ensure economic balance for the productive sector.

How companies should prepare

Regardless of any regulatory adjustments that may still arise, one conclusion is already clear: business preparation for split payment needs to begin before the new system is fully implemented.

Adaptation requires a multidisciplinary analysis involving tax, financial, accounting, technological, and strategic areas.

Companies that act early will have a greater capacity to absorb impacts, reduce operational risks, and preserve competitiveness.

This involves mapping financial flows, reviewing contracts, analyzing working capital exposure, testing technological infrastructure, and strengthening tax governance.

More than a tax change, split payment represents a structural transformation in the relationship between tax collection, operations, and business liquidity.

Businesses that treat the topic merely as a tax issue may underestimate its real impacts.

Split payment represents one of the most significant changes brought by the Tax Reform for the Brazilian business environment.

Although the model has the potential to increase tax collection efficiency, reduce tax evasion, and strengthen tax control, its effects on cash flow, liquidity, and company operations require immediate attention.

For business owners and managers, the current moment should be seen as an opportunity for strategic preparation.

Companies that structure their internal processes, tax governance, and technological capacity now will be better positioned to face the transition with security.

In a regulatory environment undergoing transformation, preventive legal counsel, combined with financial and tax planning, tends to play an increasingly relevant role in protecting business stability.