Split payment na reforma tributária brasileira: solução eficiente para o combate à sonegação fiscal ou obstáculo à sustentabilidade financeira das empresas?
Year: 2026
Type: article
Abstract: The Brazilian Tax Reform, introduced by Constitutional Amendment No. 132/2023 and regulated by Complementary Laws Nos. 214/2025 and 68/2024, promotes a profound restructuring of the consumption taxation system, replacing existing taxes with the Contribution on Goods and Services (CBS) and the Tax on Goods and Services (IBS). In this context, the split payment mechanism — consisting of the automatic division of payment in a commercial transaction, with the portion corresponding to the tax being directly remitted to the fiscal authority through integrated digital platforms and financial systems — emerges as a central instrument for automatic revenue collection and for combating tax evasion. This article analyzes, from a legal-tax and economic perspective, the feasibility, benefits, and risks arising from the adoption of split payment in Brazil, investigating whether such a mechanism represents a modernizing advance of the fiscal system or a disproportionate threat to the cash flow, liquidity, and competitiveness of companies, especially small and medium-sized ones. The research employs a deductive methodology, based on bibliographic and legislative research and international comparative analysis, taking as references the models adopted in Italy and Bulgaria. It is concluded that split payment has significant revenue potential, but its legitimacy and efficiency depend on careful normative planning, adequate technological transition, and preservation of constitutional tax principles.
Source: Revista fisio&terapia.
DOI: 10.69849/srs0d306
Institution: Universidade Presbiteriana Mackenzie
Language: English
Topic: Economic and Fiscal Studies
Subfield: Economics and Econometrics
Domain: Social Sciences
Open Access status: hybrid
OpenAlex ID: W7203655312