*By Paulo Rogério Magri
Complementary Law No. 214/2025, which regulates key aspects of the Tax Reform, introduced a significant innovation for companies: the adoption of split payment, or the payment of taxes in installments at the time of financial settlement of the transaction. Under the new mechanism, the amount corresponding to the tax due (IBS and CBS) will be automatically separated from the price of the goods and/or service and transferred in real time to the public coffers.
This drastically reduces the risk of default and undue tax withholding by the taxpayer. This aspect will affect companies' cash flow planning, as it is considerably different from the current reality, as companies end up using the tax payment deadline as part of the financing of the operation.
Relevant impacts on competitiveness
Companies that already have robust tax processes and management will have a clear competitive advantage in this model. Historically, some companies have benefited unduly from tax evasion and/or deferral, artificially lowering their prices and distorting market competition.
With split payments, this asymmetry tends to disappear. The tax will be collected before it even reaches the company's cash flow, eliminating room for irregular practices and making operational efficiency, cost management, and tax compliance true competitive differentiators.
Direct benefits for companies with good governance & management
• Competitive fairness: reduction of disparities caused by tax evasion;
• Tax planning: encouraging companies to do so, practicing tax avoidance;
• Legal certainty: mitigation of risks related to fines for incorrect and/or untimely collection;
• More predictable cash flow: simplification in the control of taxes to be paid, already deducted at source.
• Reputation and governance: strengthening the compliance image among its professionals, stakeholders, investors, regulatory agencies and others.
Chain effect simulation
Imagine a sector with three main links: Supplier → Distributor → Retail.
Today, if one link in the chain evades taxes, it can offer lower prices, putting pressure on the others.
With split payment:
1. The supplier issues the invoice and the tax is collected at the time of financial settlement of the transaction, as integrated with the payment systems;
2. The distributor receives only the net amount and also pays the tax automatically on the retail sale; and,
3. Retail operates with prices aligned with the sector's real tax burden.
Result:
• Elimination of the cascading effect of artificially reduced prices;.
• Incentive for companies to choose partners with a real history of compliance; and, • Improved predictability of margins and revenues for the entire chain, from production to consumption.
Impact on the production chain, with greater equity
In practice, production and distribution chains comprised of reputable suppliers will benefit. Immediate tax collection tends to attract partners equally concerned with tax compliance. This strengthens integration between links in the chain and raises the standard of governance and management for the sector as a whole. The mechanism can also encourage investment in tax technology and systems integration (ERP, management, and reconciliation platforms), as automation will be essential for monitoring the flow of information and bank reconciliations related to split payments.
The implementation of split payments is not just an operational change; it's a milestone that benefits tax collection and those who comply with tax rules. By leveling the playing field, Brazil takes an important step toward ensuring that effective governance and management are the true driving forces of competitiveness, also stimulating the crucial coopetition.
In this new scenario, being prepared won't be a differentiator — it's a basic, minimum requirement.
For companies with good governance and management, which are mature and robust and therefore ahead of the curve, split payments become another favorable variable, which can contribute to their financial sustainability, leadership, and longevity in the market.
And is your company prepared?
*Paulo Rogerio Magri, Managing Partner of ASPR
Notice: The opinion presented in this article is the responsibility of its author and not of ABES - Brazilian Association of Software Companies
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