Split Payment in 2027: how the CFO should redesign the cash flow

From 2027, the Tax Reform will begin to leave the conceptual field and enter the day-to-day financial life of companies. For the CFO, one of the most sensitive points will be the split payment, This is a mechanism in which part of the amount paid by the client is segregated at the time of financial settlement and directed to the collection of CBS and IBS.

In practice, this changes an old logic: the company no longer receives the gross value of the sale in full, but then assesses and collects taxes. With split payment, a portion of the cash may not even pass freely through the company's account.

And this requires a thorough review of cash flow, pricing, working capital, tax technology and financial governance.

What is split payment

Split payment is a fractional payment model. When a sale is settled, the payment service providers and institutions involved in the financial arrangement segregate the amounts corresponding to IBS and CBS and collect them directly from the IBS Management Committee and the IRS.

A Complementary Law 214/2025 provides for this segregation and collection to take place on the financial settlement date of the payment transaction, It also establishes the obligation to pay taxes in advance, including proportionally on sales made in installments. It also establishes that the anticipation of receivables does not alter the obligation to segregate and pay taxes.

In other words: if the company sells in installments, the tax impact follows each settlement. If it anticipates receivables, it needs to consider that the tax will continue to follow the logic of the original operation.

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Why 2027 is a critical year

The year 2026 serves as the initial adaptation phase for the Consumer Tax Reform, with tests and accessory obligations. In 2027, the CBS comes into effect, replacing PIS and Cofins, while the IBS continues its gradual transition in the following years.

According to the Federal Revenue Service, CBS will come into force from 2027. There is also provision for an orderly transition for Simples Nacional companies that opt for the regular regime for calculating IBS and CBS.

For the CFO, the point is not just to “pay another tax”. The point is that the cash dynamics change. The tax is no longer just an accrued future obligation, but directly affects the net amount available at the time of financial settlement.

The central change: from gross cash to immediate net cash

Today, many companies work with cash management based on gross revenue. Even if the financial department knows that taxes will have to be paid later, the money temporarily passes through the company's account.

This interval creates a kind of operational breathing space. It can be used, consciously or not, to pay suppliers, payroll, debt, commission, freight, media, stock or administrative expenses.

With the split payment, this breath tends to diminish.

The CFO needs to abandon the view of “invoiced revenue” as a proxy for available cash. The relevant metric becomes:

net operating cash after segregation of taxes, financial fees, chargebacks, prepayments and contractual retentions.

This is an important turning point. Companies that operate with tight margins, a long financial cycle or a high dependence on receivables may feel the impact before they even realize it in the income statement.

The main impacts on cash flow

1. Reduction in available cash on receipt

The most obvious effect is a reduction in the net amount received. If part of the payment is automatically directed to the tax authorities, the company loses the temporary use of this money.

This requires recalibrating liquidity projections. Cash flow models that still start from gross revenue and apply taxes only at tax due date will become dangerously optimistic.

2. Less flexibility for working capital management

Companies that use the interval between receiving and collecting taxes as an informal working capital cushion will have to find alternative sources of financing.

This dependency doesn't always appear in the traditional diagnosis. It is often hidden in practices such as occasional supplier delays, recurring card prepayments or the use of tax cash to cover seasonality.

3. New design for installment sales

LC 214/2025 provides for proportional segregation in installment payments. This changes the analysis of installment sales, especially in sectors with long installments.

The CFO will have to look not just at the total value of the sale, but at the net flow of each installment. The question is no longer “what is the average ticket?” but “how much net cash does each installment deliver, on what date and at what financial cost?”

4. Review of the policy for anticipating receivables

Anticipating receivables will continue to be an important tool, but it will need to be analyzed more rigorously.

As anticipation does not eliminate the obligation to segregate taxes according to the original transaction, the CFO must simulate the total cost of anticipation taking into account:

• gross sales value;
• segregated taxes;
• discount rate;
• average collection period;
• default or chargeback;
• net margin per channel;
• real cash requirements.

Anticipating receivables without this vision can destroy margin without structurally solving the liquidity problem.

5. Pressure on contracts and pricing

If net cash decreases at the time of settlement, poorly priced contracts become more exposed. Companies already operating with low margins will need to review prices, terms, discounts, commissions and commercial conditions.

The problem won't just be tax-related. It will be economic.

The CFO should provoke the commercial area with objective questions:

• Does this price still sustain the margin after split payment?
• Does the payment period offered to the customer match the payment period offered to the supplier?
• Is the trade discount being calculated on gross revenue or net cash?
• Is commission levied on turnover, receipts or margin?
• Is the sales channel still profitable after fees, splits, defaults and prepayments?

How the CFO should redesign the cash flow

1. Create a post-split cash flow view

The first step is to rebuild the cash flow model. It's not enough to insert a generic “taxes” line. The model needs to reflect the actual settlement of operations.

A more mature structure must separate:

• gross sales;
• highlighted taxes;
• amounts segregated via split payment;
• Acquisition fees or means of payment;
• anticipations;
• chargebacks;
• returns and cancellations;
• net receipt;
• operational obligations;
• free balance for decision.

This vision should be daily or weekly, not just monthly. The impact of the split payment will be felt in operational liquidity, and liquidity is managed in the short term.

2. Recalculate the cash conversion cycle

The CFO must review the entire financial cycle:

average inventory period + average receipt period - average payment period to suppliers.

With split payments, the average collection period needs to be analyzed in net terms. A sale received in 30 days may not deliver the same net cash as before.

This affects purchasing decisions, inventory, customer credit, promotional campaigns and commercial expansion.

3. Simulate scenarios by product, channel and customer

The classic mistake will be to treat the split payment as an average impact. A good CFO knows that averages hide problems.

The simulation must be done by:

• product or service line;
• sales channel;
• payment method;
• customer profile;
• deadline for receipt;
• tax regime;
• gross margin;
• need for working capital.

With this, the company identifies where split payment puts the most pressure: marketplaces, e-commerce in installments, long-term B2B sales, recurring contracts, labor-intensive services, low-margin operations or units with a high dependence on advance payments.

4. Redesigning commercial policies

Finance cannot leave the adaptation to split payment to the tax department. The commercial area needs to be involved.

Some practical measures:

• reduce excessive receipt times;
• create price differentiation by payment condition;
• limiting installments that squeeze cash;
• review discounts on low-margin sales;
• adjust commissions to reflect net receipt or margin;
• renegotiate contracts with tax recovery clauses;
• create allowances for commercial exceptions that affect working capital.

The aim is not to stop sales. It's to sell with a healthy cash flow.

5. Review supplier contracts

If the cash comes in leaner, the exit period also needs to be renegotiated.

The CFO should map critical suppliers and seek alignment between cash inflow and outflow. In some cases, it may make sense to exchange a cash discount for a longer term. In others, the financial discount may pay off.

The decision must be mathematical, not intuitive.

6. Integrate tax, treasury and technology

Split payment requires fine integration between tax documents, payment methods, ERP, bank reconciliation and accounting.

The company will need to ensure that the systems can reconcile:

• invoice issued;
• value of the operation;
• calculated taxes;
• segregated value;
• net amount received;
• corresponding portion;
• any return or cancellation;
• tax balance to be paid or offset.

If this integration fails, the CFO will have three problems at the same time: poorly projected cash, inconsistent accounting and tax risk.

7. Create specific indicators

Financial management must incorporate new KPIs. Some useful indicators:

• percentage of revenue segregated on receipt;
• liquid box per channel;
• net margin after splits and financial fees;
• dependence on anticipation of receivables;
• average net receipt period;
• difference between turnover and available cash;
• financial cost by payment method;
• cash exposure from installment sales;
• the impact of split payments on working capital.

These indicators should be included in the CFO's monthly package and, ideally, in weekly treasury dashboards.

The strategic role of the CFO

The CFO must not treat split payments as an operational demand of the taxman. That's the mistake.

The subject involves financial strategy, business models, systems architecture and capital governance. The CFO needs to lead a multidisciplinary front involving tax, accounting, treasury, sales, technology, legal and operations.

The minimum agenda for 2026 and 2027 should include:

• diagnosis of the current reception model;
• simulation of impact by channel and product;
• reviewing the cash budget;
• adjusting trade policies;
• renegotiation of relevant contracts;
• systems integration;
• conciliation tests;
• team training;
• creation of net cash indicators;
• contingency plan for operational failures in the transition.

Risks for companies that procrastinate

Companies that don't react until 2027 could be in trouble:

• negative liquidity surprise;
• increased need for working capital;
• greater dependence on expensive credit;
• falling margins due to poorly priced contracts;
• manual reconciliations and tax errors;
• tension between financial and commercial;
• loss of competitiveness in channels with long lead times;
• difficulty in explaining cash variations to the board or shareholders.

The tax transition will be gradual, but the management impact could be immediate for those who fail to prepare.

Conclusion

Split payment is not just a change in the way IBS and CBS are collected. It's a change in the way the company should view the money that comes in.

For the CFO, 2027 will be the year to change the mental model of gross sales for the model of net cash available. Those who do this early will have an advantage: they will be able to adjust prices, terms, contracts, systems and working capital with more control.

Anyone who waits for the problem to appear on their bank statement will be negotiating under pressure.

The best approach now is simple: simulate, measure, redesign and integrate. The CFO who leads this agenda will not just be complying with the Tax Reform. They will be protecting liquidity, margin and financial predictability in a new tax environment.

How CLM Controller can support your company

Split payment shouldn't just be treated as a change in tax collection. It requires a practical review of cash flow, working capital, reconciliation, contracts, systems and management indicators.

CLM Controller supports companies in preparing for the Tax Reform, connecting accounting, tax and financial vision to transform regulatory changes into practical management decisions.

In practice, this includes:

• diagnosis of the impacts of the Tax Reform;
• reviewing tax and accounting processes;
• analysis of the impact on cash flow;
• support for structuring financial indicators;
• guidance for improving governance;
• advisory support for decision-making.

For CFOs, finance directors and entrepreneurs, the ideal time to review these points is before the new mechanisms are fully implemented. The sooner the company understands the effect of split payments on cash, the greater its ability to protect margin, liquidity and predictability.