With the arrival of the Tax Reform, the introduction of the Goods and Services Tax (IBS) and the Contribution on Goods and Services (CBS) marks a structural change for the business environment in Brazil. Among the mechanisms foreseen, the so-called split payment, or disaggregated payment, is perhaps one of the most disruptive provisions from an operational, financial, and systemic point of view.
In this new model, the tax amount is automatically segregated at the time of the transaction and directly remitted to the tax authorities. The supplier, therefore, only receives the net amount. While the proposal aims to combat tax evasion and optimize revenue collection, it requires significant revisions to business processes and creates substantial uncertainties, particularly for leaders in finance, sales, tax, logistics, and technology.
Because, in practice, split payment requires a new cash flow design, pricing, systemic governance, and contractual renegotiation. Therefore, senior management is placed in a position of leadership and operates not just as support for the fiscal transition, but as a strategic agent to ensure continuity, liquidity, and resilience.
The companies' cash flow will be directly affected. With the net value being lower, there will be a need to re-evaluate working capital, revise financial projections, and renegotiate bank limits, including because financial predictability, an essential element for results, will be compromised initially.
Furthermore, supplier liquidity can also be impacted, affecting delivery schedules and logistics contracts. Interdependent chains, such as distribution and resale, can experience operational disruptions; and the reduction in net receivables may force price adjustments, discounts, and commission changes, leading to contract revisions with major clients and impacting margins.
Reconciling what is retained, passed on, and recorded now requires intensive digital governance and increased investment in internal controls. A technical error can quickly turn into a fiscal and reputational liability.
It's important to emphasize that ERPs, payment gateways, tax, and accounting modules will need to be seamlessly integrated end-to-end to handle tax dismemberment. Companies with multiple systems or low digital maturity will face high integration costs and the risk of inconsistencies.
Practical uncertainties still greatly concern the market.
Despite the general guidelines, several operational scenarios still lack clear practical definitions of how they will function under the split payment regime. This increases complexity and raises concerns for business leaders.
Some questions raised concern how returns will be handled after the tax has already been collected. How will the process work for adjustments in cases of bonuses, trade discounts, or cancelled invoices? Will there be an automated path for refunds of incorrectly paid taxes or recoverable amounts? Will the tax system be prepared to handle the volume and diversity of transactions in real time?
These unanswered questions indicate that the impact of split payment extends beyond the fiscal sphere. It affects the core of operations and the operational margins of companies, requiring process review, cost restructuring, and redesign of the value chain.
For senior management, this means acting proactively by evaluating simulated financial scenarios, assessing budget impacts, and evaluating the company's ability to absorb cash flow fluctuations. After all, all this complexity ultimately translates to results, which depend directly on cash flow.
This new scenario requires companies to prepare proactively, conducting simulations and reviewing values using external calculation solutions, to ensure tax compliance, centralize tax regulations, and guarantee that segregated, credited, and reconciled amounts are fully compliant with current legislation. After all, if even today there are withholdings and bureaucracy for taxpayers to recover amounts rightfully theirs, imagine the impact and complexity in a system structured around split payment.
With this, companies have realized several advantages, such as reduced human error and rework, faster adaptation to legal changes without system downtime, integration with ERPs and multiple management systems—essential for large-scale operations—and improved fiscal and financial predictability.
Tax Reform, and especially split payment, should be understood as a new chapter in corporate governance. CEOs, CFOs, COOs, and leaders of critical areas need to take the lead immediately, promoting a systemic response commensurate with the complexity involved.
Still think this topic is just a challenge for the fiscal and IT departments? Split payment proves otherwise. It redefines processes, impacts pricing decisions, cash flow, investments, and even how the market perceives the company. Those who don't take the lead now will discover too late that they may have lost control.
Thais Borges is the Head of Commercial and Marketing. Systax, A company that develops technological solutions focused on the tax market.
