Brazil's economic team has accepted paying banks R$0.39 per transaction to operate the "split payment", the tax reform mechanism that withholds consumption taxes at the moment of payment, before the money reaches the seller. The decision came from an interministerial working group set up to discuss how the federal tax collection network will be paid, and it is not final, according to g1. The group's report says the matter still awaits legal, budgetary and political review, including how any payment would be formalized.
The scale of the system explains the fight over the number. The government itself told g1 that once fully implemented the system should process 1.3 billion to 1.5 billion operations per year, moving about R$6 trillion. At R$0.39 per transaction, annual bank remuneration would land between R$507 million and R$585 million. Sources told g1 that early negotiations involved higher figures, which the government rejected.
The split payment is a module of the Federal Revenue Service's new system. It sends the tax on each sale in real time to the federal, state and municipal governments, aiming to curb tax evasion. The seller receives the amount already net of tax, and the system promises to refund credits for taxes paid in earlier stages of the production chain within hours. The proposal under study pays the fee only after deducting the banks' float, the period, usually one day, when the funds sit in bank cash before reaching the government; in that window banks also invest the money and earn a return. For the Confederação Nacional das Instituições Financeiras (Fin), the banking trade group that sits on the working group, the fee compensates "relevant investments" in technology, infrastructure and security. The group gave no numbers.
Resistance inside government
The Controladoria Geral da União (CGU), Brazil's federal audit office and also a member of the group, reportedly opposed the R$0.39 figure, according to g1. Asked about it, it said only that the "proposal in question is under analysis". The news site JOTA reported in early August that the audit office questioned the calculations, warned that the remuneration could exceed the sector's costs and noted that the model under consideration would be barred by law. The Finance Ministry said the report is "technical and will only inform the political decision of minister Dario Durigan". Because the split payment will also collect the IBS, the tax of states and municipalities, any definition must be agreed with the CGIBS, the committee that manages that tax. It had not responded to g1 by the story's last update.
Who pays the bill
Tax lawyer Bruno Medeiros Durão, who also specializes in banking law, says banks will have to overhaul their technology to talk to the Federal Revenue Service in real time, which would justify a per-transaction fee. The question, he says, is where the cost ends up.
"The split payment solves a real problem, which is evasion in tax withholding, but it creates another one, and someone has to pay for the infrastructure that enables this control in real time. When this bill falls on the financial system, it tends to be passed on, directly or indirectly, to whoever is at the end of the chain, whether the shopkeeper or the final consumer."
Durão also warns of litigation if the fee's calculation method is not transparent, and says the CGU's questioning shows the criteria still need stronger technical grounding.
The deadline is tight. The fee must be settled by the end of this year, because the split payment starts to apply in 2027, gradually and on an optional basis, to operations of the CBS, the new federal consumption tax created by the reform. The Federal Revenue Service has already told g1 that the mandatory phase for business to business sales should only arrive in 2028, after more than 200 financial institutions join through 2027. For companies, the mechanism holds the tax at the moment of sale and squeezes working capital exactly during the adaptation to the reform, though it promises same-day refunds of credits. For consumers, the risk flagged by the specialist is that the fee filters into final prices.