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 disaggregated payment, is perhaps one of the most disruptive provisions from an operational, financial, and systemic perspective.
In this new model, the tax value is automatically segregated at the time of the transaction and remitted directly to the tax authority. The supplier, therefore, receives only 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 uncertainty, particularly for leaders in the finance, sales, tax, logistics, and technology departments.
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 position of leadership and operates not only as a supporter of the tax transition, but also as a strategic agent to ensure continuity, liquidity, and resilience.
Company cash flow will be directly impacted. With the net value being lower, working capital will need to be re-evaluated, financial projections revised, and banking limits renegotiated, 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 suffer operational disruptions; and the reduction in net receivables may force price adjustments, discounts, and commission revisions, leading to contract reviews with major clients and impacting margins.
Reconciling what is retained, passed on, and recorded now requires intense digital governance and increased investment in internal controls. A technical error can quickly translate into a fiscal and reputational liability.
It's important to emphasize that ERPs, payment gateways, tax, and accounting modules will need to be integrated end-to-end to handle tax disaggregation. 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 red flags for business leaders.
Some questions raised center around how returns will work after the tax has already been collected. How will the adjustment process be handled in cases of bonuses, trade discounts, or invoice cancellations? Will there be an automated channel for refunds of improperly paid taxes or amounts to be recovered? 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 operations and operational margins of companies, 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 the company's ability to absorb cash flow fluctuations. After all, this complexity ultimately translates into results, which are directly dependent on cash flow.
This new scenario requires companies to prepare in advance by performing 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 for taxpayers to recover amounts due to them today, imagine the impact and complexity in a system structured around split payment.
With this, companies have realized several advantages, such as reduced human errors 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 business areas need to take the lead immediately, promoting a systemic response appropriate to the complexity involved.
Still think this topic is just a challenge for tax 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 Commercial and Marketing Director Systax, Company that develops technological solutions for the tax market.
