Split payment also provides for refunds, and the regulation has already been issued
Those who follow the implementation of split payment usually focus on the moment when money leaves the supplier's hands toward the Tax Authority. But there is a reverse flow, less discussed and equally relevant for those who operate tax and financial systems: what happens when a sale is canceled or a product is returned after IBS and CBS have already been segregated in the financial settlement of the transaction.
(cite index="20-5,20-6">The legal basis is Complementary Law 214/2025, sanctioned on January 16, 2025 and amended by Complementary Law 227/2026, which (cite index="39-1">authorized the regulation to provide for the transfer to the supplier of the amount collected via split payment in cases of return, a discipline incorporated both for CBS (Decree 12,955/2026) and for IBS (CGIBS Resolution 6/2026).
Cancellation and return are not the same thing for the Tax Authority
The regulation separates the two scenarios with technical precision: (cite index="24-1">Article 57 of the CBS Regulation, replicated for IBS by CGIBS Resolution No. 6/2026, distinguishes cancellation (reversal before delivery) from return (reversal after delivery) and subjects both to a mandatory documentary process, requiring a proper tax document for every reversal. In other words, it is not enough to reverse an internal entry: the reversal of a debt extinguished by split payment depends on a specific tax document, correctly issued by the originating system.
Three-business-day deadline and cash refund, not credit
When the debt of the original transaction has been extinguished by split payment, the refund to the supplier follows a different logic than tax credit offsetting. (cite index="26-1">In the return or cancellation of a transaction whose debt was extinguished by split payment, the amount collected returns to the supplier in cash, within up to three business days from the debt reversal or from the date on which credit appropriation would be permitted, and it is prohibited to use this amount as a credit, since the recomposition occurs in cash. For tax teams, this means monitoring a new type of account receipt that is neither a sale nor a tax credit reversal: it is a cash refund, with a specific deadline and origin.
The point that still raises questions: receivables already assigned to fintechs and FIDCs
The complexity grows when a company advances receivables through factoring, receivables fintechs, or credit rights investment funds (FIDCs). (cite index="42-2,42-3,42-4">The supplier indicated in the Segregation Report may have already sold the credit and received the assignment price in advance, but, for tax purposes, it remains the party to the original transaction, and if there is a cancellation or return with the amount collected via split payment transferred to that supplier, an economic misalignment may arise. In practice, (cite index="42-9,42-10">this risk tends to appear in the discount rate, with funds and financial institutions reducing the price paid for the receivable or requiring recomposition mechanisms according to the degree of exposure to segregation.
Lawyers following the topic already recommend immediate contractual action: (cite index="43-1">the contract must expressly state to whom the amount refunded by the tax authority belongs in case of cancellation or return, and within what timeframe it must be passed on to the assignee. Companies with a high volume of installment sales, installment card payments, or receivables advancing should review these clauses before the mechanism is fully adopted.
What this already requires from the ERP and tax routine
Even though 2026 is the testing year, with a symbolic rate, the architecture is already defined. This already requires practical adjustments:
Automatic issuance of the reversal tax document linked to the original transaction, without relying on manual entry, respecting the distinction between cancellation and return required by the regulation.
Reconciliation of a new type of financial inflow: amounts refunded via split payment within up to three business days, which cannot be confused with sales revenue or credit appropriation.
Traceability of assigned receivables, so that the finance team knows, at any time, who is the supplier indicated in the Segregation Report and who economically holds that credit, avoiding surprises in cancellations.
(cite index="13-2,13-3">The integration brings together information that today flows through different processes within companies — tax document, tax obligation, and payment — which should require attention from accounting, tax, finance, and technology teams, as well as adaptations to the ERPs themselves.
Where this fits into the reform's timeline
The technical infrastructure is already advancing: (cite index="30-5,30-8">on June 3, 2026, the Federal Revenue Service and the IBS Management Committee published in the Federal Official Gazette Joint Act RFB/CGIBS No. 2/2026, which officially made available the technological documentation (Integration Manual and Swagger) that will serve as the basis for collecting the new taxes. And the general timeline remains firm: (cite index="12-3">2026 is the operational testing year, with a symbolic rate of 1% (0.9% CBS + 0.1% IBS), the effective implementation of CBS occurs in 2027, while IBS follows a longer transition until 2032/2033.
This content is for informational purposes only and does not replace guidance from your accounting team, which should assess the specific impact of these rules on your company's operations. If your team wants to understand how to prepare the ERP for these split payment changes, talk to Edoo.
Split payment: how the IBS/CBS refund works in cancellations and sales returns