InícioLegislationTax reform introduces split payment and non-cumulativeness; expert guides companies through new...

Tax reform introduces split payment and non-cumulativeness; expert guides companies through new scenario

With the tax reform regulated this year and set to take effect in 2026, Brazil is about to enter a new tax era. One of the pillars of this transformation is the “split payment” system. But what does it mean, in practice, to divide tax payments directly at the source, as the legislation proposes? And how does this connect to the much-discussed non-cumulative nature of taxes?

For tax expert Lucas Ribeiro, CEO of ROIT, a technology and consulting company leading the development of solutions for the Tax Reform, the moment calls for unraveling and understanding “split payment.” “After all, it’s a model that could revolutionize corporate finances,” he considers.

Split payment: the revolution in tax collection

The “split payment” is a mechanism that promises to bring more security and efficiency to the Brazilian tax system. In it, the due tax is segregated at the time of payment and directed straight to the tax authorities, reducing the risks of default and tax evasion. “The ‘split payment’ eliminates tax evasion but requires greater working capital availability for companies,” explains Ribeiro.

This model is already used in some European countries, such as Italy and Poland, where it helped combat tax evasion and improve collection, even if it only applies to some operations. In Brazil, its adoption comes with technological and operational challenges but promises to change the game for businesses and public administrations.

Non-cumulativity: the principle supporting the Brazilian VAT

The non-cumulative nature of taxes, enabled by the tax reform, ensures that taxes are only levied on the value added at each stage of the production chain. With the creation of the Dual Value-Added Tax (VAT) by the reform (which integrates two taxes, CBS, Contribution on Goods and Services, and IBS, Tax on Goods and Services), companies will be able to offset credits generated from purchases against sales liabilities, avoiding cascading taxation and current cumulativity.

The challenge lies in the practical application of this principle, Ribeiro assesses. “Non-cumulativity seems simple, but its operationalization requires the basics: buying everything with invoices and recording them correctly. A major shift in culture, processes, and systems will be essential,” he emphasizes.

The tax expert lists some points companies will need to master to better leverage the achievements of the tax reform:

  • Automation of tax processes: companies that invest in technology to automate the full cycle of tax recording and payments will be ahead.
  • Strategic credit management: knowing how to calculate and use credits efficiently will be essential to maximize profit margins.
  • Contractual adaptation: contracts with suppliers and clients need to be reviewed to reflect changes in tax rates and payment methods.
  • Team training: understanding the new tax model will be a competitive edge. Accounting and finance professionals need to update their knowledge.

With “split payment” and non-cumulativity, Brazil is moving toward a more efficient tax model aligned with international practices. However, implementation will be challenging and will require planning, reliable data, and cutting-edge technology. “Those who master the numbers and understand the nuances of this new system will have an undeniable competitive advantage. And this starts now, in 2025, with companies preparing before it’s too late,” highlights Ribeiro.

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