On June 3, 2026, Joint Act No. 2 of May 27, 2026 — issued by the Brazilian Federal Revenue Service (Receita Federal do Brasil — RFB) and the IBS Management Committee (Comitê Gestor do IBS — CGIBS) — was published in the Federal Official Gazette (Diário Oficial da União). The act authorized the release, on the National Portal for the Taxation of Goods and Services, of the Integration Manual and the Swagger documentation — the technical specification of the application programming interfaces (APIs) — for the Public Split Payment Platform. Split payment is the mechanism contemplated by Constitutional Amendment No. 132/2023 (Emenda Constitucional nº 132/2023) and governed by Complementary Law No. 214 of January 16, 2025 (Lei Complementar nº 214/2025 — “LC 214/2025”). Under it, the State-Municipal Goods and Services Tax (IBS) and the Federal Contribution on Goods and Services (CBS) are withheld and remitted to the government at the moment each transaction is paid electronically, without passing through the supplier’s cash position.
The Joint Act creates no new substantive law: it authorizes the publication of technical documentation. Its significance, however, is concrete. For the first time, it is possible to observe — in data fields and message flows — how the mechanism has been designed to operate. For companies, the change is, above all, one of cash flow and credit dynamics. It should be noted at the outset that what follows is an interpretation based on the rules published to date — LC 214/2025, Decree No. 12,955/2026 (
Decreto nº 12.955/2026), and CGIBS Resolution No. 6/2026 — and on the
technical documentation released, which remains a work in progress. Important operational details depend on further implementing acts.
Given the significance of the subject, this article goes somewhat further than our usual commentary — in particular, to examine how, in practice, the purchaser is to remit the tax owed by the supplier, to the extent that the rules published to date allow. The principal aspects are examined below.
What changes in a company’s cash flow — and in its tax credits?
Split payment is neither a new tax nor a higher rate — it changes the “when” and the “how” of collection. Today, a company receives the full sale amount and only remits the tax on the due date, days or weeks later; during that interval, those funds circulate within the business. With split payment, this cash-flow cushion — the so-called tax float — disappears, and the supplier receives the net amount. In our view, the principal effect is not one of tax burden, but of accelerated cash outflow, with a direct impact on working capital, particularly in sectors with thin margins and long collection cycles.
There is a second effect, less visible and equally relevant, on tax credits. Under the new system, the purchaser’s IBS and CBS credit does not arise fully formed. Decree No. 12,955/2026 distinguishes three stages: a credit pending appropriation (crédito a apropriar), being the expectation of a credit arising from a valid tax document whose corresponding debit has not yet been extinguished; an appropriated credit (crédito apropriado), available for offset or refund once the applicable requirements have been met; and a utilized credit (crédito utilizado). The transition from “pending appropriation” to “appropriated” depends, as a rule, on the extinguishment of the corresponding debit at the previous stage of the chain. This may be termed conditional non-cumulativity: the purchaser’s credit is tied to the actual collection of the tax on the prior transaction, and it is precisely this logic that split payment automates.
How does the payment method determine the form of collection?
The form in which split payment operates depends on who initiates the payment transaction and on the method used. Decree No. 12,955/2026 distinguishes transactions initiated by the payee (the supplier, who issues the charge) from those initiated by the payer (the purchaser, who initiates the payment). Two forms of withholding follow from this distinction:
- In arrangements initiated by the payee — the bank payment slip (boleto), dynamic-QR-code Pix (Pix being Brazil’s instant payment system), and recurring Pix (Pix automático) — a charge is registered before payment. This interval allows the payment provider to query the public platform and withhold the exact amount of tax, already accounting for the supplier’s credits, before releasing the funds. This is the modality that the technical documentation refers to as “super-intelligent”;
- In arrangements initiated by the payer — static-QR-code Pix, Pix by key or by bank-account details, electronic wire transfer (TED), and point-of-sale electronic funds transfer (TEF) — the transaction arises at the moment of payment, with no prior charge. In these cases, withholding is based on the amount reported in the transaction itself, with any adjustments made afterward. This is the “intelligent” modality, without real-time correction.
One practical point is worth highlighting: in arrangements initiated by the payer, it is the purchaser who reports the tax amount. The supplier therefore depends on the purchaser entering the data correctly in the payment order, and must provide that data in advance — in the tax document or through an integrated system. Credit and debit cards and vouchers, it should be noted, enter at a later implementation stage. In all of these cases, the CBS is withheld and remitted to the RFB and the IBS to the CGIBS, each authority being responsible for its own tax.
What happens if the tax information does not accompany the payment?
This is, in our view, the most sensitive point of the new system. If a transaction is initiated without identifying the tax amount, the simplified procedure is triggered automatically (Article 30 of Decree No. 12,955/2026), with two consequences:
- the tax is withheld at a fixed percentage, set by a joint act of the RFB and the CGIBS, which, under Article 30, paragraph 2, item III, of the Decree, bears no relation to the amount actually due on the transaction;
- collection through this route, under Article 30, paragraph 7, item II, of the Decree, does not generate a credit for a purchaser that is a taxpayer under the regular regime.
In our view, the most immediate practical risk is not over-withholding, but the breakdown of non-cumulativity through an information failure. In commercial terms, a supplier whose transactions repeatedly fall into the simplified procedure will tend to pass a cost on to its customer, who loses the credit. For these reasons, ensuring that the tax amount and the link to the tax document always accompany the payment ceases to be a technical detail and becomes a condition of tax efficiency and competitiveness.
How, in practice, is the purchaser to remit the tax owed by the supplier?
Not every payment passes through an electronic method capable of withholding the tax. For such cases, LC 214/2025 and Decree No. 12,955/2026 provide for remittance by the purchaser (recolhimento pelo adquirente) — one of the five methods of extinguishing an IBS and CBS debit (Article 27 of LC 214/2025; Article 26 of the Decree). This is the scenario in which the purchaser itself remits to the government the tax that is, in principle, owed by the supplier. It is worth tracing what the published acts already allow us to state about its mechanics.
Scope and eligibility (Article 36, caput). Under Article 36 of LC 214/2025, mirrored in Article 36 of the Decree, a purchaser that is a taxpayer of the IBS and CBS under the regular regime may pay the IBS and CBS due on the transaction where payment to the supplier is made through an instrument that does not permit automatic withholding — that is, outside the split-payment scenarios of Articles 32 and 33 of LC 214/2025. The option is therefore limited: it does not extend to the final consumer or to a purchaser outside the regular regime.
How the option is exercised (Article 36, paragraph 1). Here is a point that often goes unnoticed. Under Article 36, paragraph 1, of LC 214/2025, the option
“shall be exercised exclusively through the remittance, by the purchaser, of the IBS and the CBS due on the transaction.” There is, therefore, no separate election form or filing — the very act of remitting the tax on that transaction is how the option is exercised.
Treatment of the amount remitted (Article 36, paragraph 3). Article 36, paragraph 3, of LC 214/2025 provides that the amount remitted by the purchaser:
- shall be used exclusively to pay the IBS and CBS debits not yet extinguished in respect of those transactions; and
- to the extent it exceeds the amount so used, shall be transferred to the taxpayer — the supplier — within three business days.
Unlike the methods of offset and of payment by the taxpayer — in which the extinguishment of debits is allocated in the chronological order of the tax document — under remittance by the purchaser the extinguishment is tied to the specific transaction (Article 27, sole paragraph, item II, of LC 214/2025; Article 26, paragraph 1, item II, of the Decree). In other words, the payment made by the purchaser settles the debit of that specific transaction.
And the purchaser’s credit? This is the mechanism that makes the method neutral for the purchaser. As noted above, a credit “pending appropriation” becomes an “appropriated” credit upon the extinguishment of the debit at the previous stage. Under remittance by the purchaser, it is the purchaser itself that extinguishes that debit, so that, in remitting the tax on the transaction, it simultaneously satisfies the condition for appropriating the corresponding credit. This is mechanically distinct from the simplified procedure, in which remittance — by the express provision of Article 30, paragraph 7, item II, of the Decree — does not generate a credit. For this reason, it is our understanding that remittance by the purchaser, where available, is the route that preserves non-cumulativity, in contrast to falling into the simplified procedure.
Monitoring by the supplier (Article 36, paragraph 4). Because the party remitting the tax is not the holder of the debit, LC 214/2025 provides, in Article 36, paragraph 4, that the CGIBS and the RFB will establish a mechanism allowing the supplier to monitor the remittance made by the purchaser. Such a mechanism is necessary for the supplier to confirm the extinguishment of its debit on that transaction and the resulting regularity of the chain.
How far the published acts allow us to go. The boundary between what has already been defined and what has not should be drawn clearly. The published acts — LC 214/2025 and Decree No. 12,955/2026 — define who may remit the tax, in what scenario, how the option is exercised, the treatment of the amount remitted, the tie to the specific transaction, the return of any excess within three business days, and the contemplated supplier-monitoring mechanism. They do not, however, define decisive operational aspects: which tax collection voucher the purchaser is to use, the deadline for such per-transaction remittance, the interface through which it is to be made, and how it is to be integrated with the assisted assessment of the IBS and CBS. In our view, these points depend on a joint act of the RFB and the CGIBS that has not yet been published. It should further be noted that the Integration Manual and the Swagger documentation released by Joint Act No. 2/2026 govern the Public Platform for split payment operated by payment institutions — and not the manual remittance by the purchaser, which follows a separate route that is yet to be detailed.
What remains unsettled — and how to prepare?
The technical documentation is a significant advance, but it does not close the regulatory cycle. The following points, among others, remain pending:
- the precise timetable for each implementation stage, still dependent on a joint act of the RFB and the CGIBS;
- the percentages for the simplified procedure, by economic sector;
- the operational form of remittance by the purchaser — voucher, deadline, and interface — together with the supplier-monitoring mechanism;
- the technical specifications on the financial-system side and the certification of payment providers;
- the mechanics of cancellation and reversal, and of separating the net amount in instant (Pix) transactions, as well as the treatment of cross-border transactions.
In our view, the conceptual design is already sufficiently clear for companies to begin preparing, even though full rollout is expected over the course of 2027. Four fronts warrant attention now. On the tax front, ensuring that every electronic tax document carries the stated IBS and CBS amounts and the link to the payment transaction. On the financial front, recalibrating cash-flow projections for net receipts and reviewing receivables-discounting arrangements. On the technology front, planning the integration among internal systems, payment methods, and the public platform, as well as the new reconciliation routines among sales, receipts, and the tax amounts actually withheld. And on the contractual front, revisiting clauses with suppliers to address tax compliance and the protection of credits, including for situations in which collection depends on the conduct of the other party.
We are following the development of this matter and remain available to discuss the practical implications of these developments for each company’s operations. 