With the arrival of the Tax Reform, the introduction of the Tax on Goods and Services (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 "desmembrado" payment, is perhaps one of the most disruptive provisions from an operational, financial, and systemic perspective.
In this new model, the tax amount is automatically segregated at the time of the transaction and remitted directly to the tax authority. The supplier, therefore, only receives the net value. While the proposal aims to combat tax evasion and optimize revenue collection, it requires significant revisions to business processes and creates substantial uncertainties, especially for leaders in finance, sales, tax, logistics, and technology.
This is because, in practice, split payment requires a new cash flow design, pricing structure, systemic governance, and contractual renegotiation. Therefore, senior management is placed in a pivotal role and transitions from simply supporting the fiscal transition to becoming a strategic agent ensuring continuity, liquidity, and resilience.
Companies' cash flow will be directly affected. With the net amount being lower, there will be a need to re-evaluate working capital, revise financial projections, and renegotiate bank lines, including because financial predictability, a crucial 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, may experience operational disruptions; and the reduction in net amounts received may force price adjustments, discounts, and commission revisions, leading to contract reviews with major clients and impacting margins.
Reconciling retained, passed-on, and recorded information now requires significant digital governance and increased investment in internal controls. A technical error can rapidly translate into fiscal and reputational liabilities.
It is important to emphasize that ERPs, payment gateways, fiscal, and accounting modules will need to be 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 a clear definition of how they will function in practice under the split payment regime. This increases complexity and raises concerns for business leaders.
Several questions arise regarding how merchandise returns will be handled after the tax has already been collected. How will adjustments be made in cases of bonuses, commercial discounts, or cancelled invoices? Will there be an automated process for the refund of improperly 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 goes beyond the fiscal sphere. It affects the core of operations and the operational margins of businesses, requiring process review, cost restructuring, and redesign of the value chain.
For senior management, this means acting proactively, evaluating simulated financial scenarios, assessing budget impacts, and evaluating the company's ability to absorb cash flow variations. After all, all this complexity boils down, at the end of the day, to results, which depend directly on cash flow.
This new landscape requires businesses to prepare in advance, conducting simulations and reviewing values using external calculation solutions, in order to ensure tax compliance, centralize fiscal rules, and guarantee that segregated, credited, and reconciled amounts are fully compliant with current legislation. After all, if there are already withholdings and bureaucracy today for taxpayers to recover amounts due to them, imagine the impact and complexity in a system structured around split payment.
With this, companies have recognized several advantages, such as reducing human errors and rework, enabling faster adaptation to legal changes without system downtime, integration with ERPs and multiple management systems, which are essential for large-scale operations, and improved fiscal and financial predictability.
The Tax Reform, and particularly 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 Director of Sales and Marketing. Systax, Company that develops technological solutions for the tax market.
