A new chapter in Split Payment engineering
In recent weeks, the Consumption Tax Reform has entered a discussion that goes far beyond NF-e layouts or technical note deadlines: how much will it actually cost to operate Split Payment, the mechanism that will automatically segregate IBS and CBS at the moment of financial settlement of each sale. A working group formed by members of the Ministry of Finance, the Office of the Comptroller General (CGU), and the banking sector, represented by Febraban and the National Confederation of Financial Institutions (Fin), set the amount of R$ 0.39 as a proposal to compensate for each transaction processed by the system.
Where the number comes from
The figure was not chosen at random. Febraban and FIN, with support from consulting firm EY, estimated that the operational cost for institutions would range between R$ 0.46 and R$ 0.61 per transaction, potentially dropping to R$ 0.39 with a faster expansion of the system. As a reference parameter, the government decided to adopt this floor value, using as a benchmark the compensation paid by the state of São Paulo to the banking network for collecting IPVA (R$ 0.43 per operation), although it acknowledges that operating split payment is more complex.
The scale of the project helps explain why the topic matters so much to those working with tax systems. The working group's estimate points to an annual volume between 1.3 billion and 1.5 billion transactions processed by Split Payment, and 229 banks and payment companies will need to connect their systems to the Federal Revenue Service's platform — currently, about 30 institutions are part of the federal tax collection ecosystem. The financial volume is also significant: the official projection indicates that between 1.3 billion and 1.5 billion annual transactions will pass through the system, moving around R$ 6 trillion.
How payment to banks would work
A relevant technical point for those monitoring the public budget is the form of compensation. Compensation to banks would not be paid in cash, but in the form of tax credits eligible for deduction from IBS and CBS over ten years, adjusted by the Selic rate. According to the technical details, the working group concluded that the best way to make this payment is through a tax or financial credit, since it would be very difficult to create and maintain a budget line item dedicated to this; in addition to per-operation compensation (Opex), the proposal also provides for compensating the initial investments (Capex) needed to adapt the systems.
The CGU's questions
The proposal is still far from a consensus. According to the CGU, there is no technical methodology or calculation record justifying the R$ 0.39 per-transaction value; the comparison with São Paulo's IPVA compensation may serve as an initial reference, but is not sufficient since it fails to reflect the differences between the two collection models. There is also criticism regarding the uniformity of the rate: adopting a single value for all operations could result in payouts exceeding actual costs, given the different levels of complexity by processing type and the financial revenue banks obtain from the so-called float — the income an institution earns by temporarily holding funds before passing them on to the government. In addition, the oversight body highlighted restrictions under the Fiscal Framework regarding the creation of tax discounts during years of budget deficit.
Why this matters to those handling tax, accounting, and IT
For teams currently dedicated to configuring ERPs, tax document issuers, and bank reconciliation, this discussion carries two practical takeaways. First, the timeline remains as already mapped out: split payment begins on an optional basis in 2027, restricted to transactions between taxpayers under the regular regime. Second, and perhaps more important for internal planning, the model already signals a structural change in companies' working capital: in the corporate environment, the change eliminates the period during which tax money remained in the company's cash flow until the payment slip's due date, requiring a restructuring of financial management within companies.
In practice, this means the tax and finance teams will need to work more closely together: reconciling the gross sale value, the net value actually received after tax segregation, and the accounting records will depend on close integration between the ERP, bank statements, and tax documents. Systems that currently handle these three domains separately will need to evolve to deal with settlements that are already net of tax, rather than the full sale value followed by a later tax payment.
What remains open
It's worth reinforcing that the R$ 0.39 figure is a proposal under review, not a published rule. The proposal was finalized at the end of July by the working group established by the Ministry of Finance and is now under review by the Ministry itself. While the discussion about the cost of split payment progresses behind the scenes, the mandatory timeline for including IBS and CBS on electronic tax documents continues its normal course, and companies under the regular regime have already been dealing with the test rate on DF-e since August 3.
The practical recommendation for tax and IT teams is to closely monitor upcoming joint acts from the Federal Revenue Service and CGIBS regarding the Public Split Payment Platform, since any decision on fees or integration models is likely to directly impact the financial reconciliation architecture that ERPs will need to support starting in 2027.
This content is for informational purposes only and does not replace guidance from your accounting firm or a specialized tax consultant, especially given that this is a topic still under discussion and subject to change.
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Split Payment: R$0.39 per-transaction proposal to banks reignites debate over cost and cash flow ahead of 2027