Tax Reform 2025: Practical Guide for Entrepreneurs, Directors and Controllers
Por Guilherme PagottoIs your cash flow prepared to lose 20 days of working capital in 2026? The Tax Reform approved by LC 214/2025 (EC 132/2023 regulation) is not just about new rates: it's about your business's financial survival. This strategic guide goes beyond basics and details Split Payment, the Simples Nacional B2B dilemma, and immediate actions for CFOs and controllers.
The End of Cash Flow as We Know It: Split Payment
Forget the current model where you sell today and pay taxes on the 20th of the next month. With Split Payment, provided in LC 214/2025, CBS and IBS collection will occur at the moment of financial settlement of the transaction.
When swiping a card or receiving a PIX, the bank/acquirer will automatically separate the tax portion and send it to the government. Your company receives only the net value.
The "fiscal working capital" (tax money used to rotate operations for ~20 days) will cease to exist. Industries and retailers will need to review all treasury management.
The Simples Nacional B2B Dilemma
If your company is Simples Nacional and sells to other companies (B2B), you run a serious risk of loss of competitiveness.
Real Profit/Presumido clients will prefer suppliers generating "full" credit (estimated at 26.5%). Under general rules, Simples companies transfer only credit on effectively paid value (much lower), making their products "more expensive" at the buyer's end.
The strategic solution might be the "Hybrid Simples": opting to pay IBS/CBS "outside" the simplified regime (like a normal company) to generate full credits and not lose major B2B contracts. This decision requires complex tax modeling.
Fundamental Principles (Recap)
ICMS, ISS, PIS, Cofins and IPI fade away gradually.
IBS (State/Municipal) + CBS (Federal) totaling estimated 26.5% to 28% rate.
Surcharge on harmful products: cigarettes, alcohol, sugary drinks, iron ore, oil and polluting vehicles.
Action Timeline for CFOs
Strategic Timeline
2025 (PLANNING)
Tax modeling (Real vs. Presumido vs. Hybrid Simples) and long-term contract review.
2026 (TESTING PHASE)
Start of CBS (0.9%) and IBS (0.1%) collection. Approval of new ERPs for Split Payment.
2027 (KEY TURNING POINT)
Extinction of PIS/Cofins. CBS enters with full rate. Cash flow impact will be felt here.
2029-2032 (TRANSIÇÃO)
Gradual reduction of ICMS/ISS and increase of IBS.
2033 (FINAL MODEL)
Full vigor of new system.
Strategic Decisions Required
End of state tax benefits (Fiscal War) may make current location inefficient. Re-evaluate logistics.
Your ERP needs to "talk" to banks for Split Payment. Legacy systems won't support new complexity.
Pricing will need to be rebuilt from scratch, considering full non-cumulativity and financial credit.
Conclusion: The Cost of Inertia
Tax Reform is not a future event, it is a present reality in balance sheets of those already adapting. Companies ignoring Split Payment impact or Simples credit dynamics will lose margin and market share. The time to simulate scenarios is now.
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Guilherme Pagotto
Diretor Tributário
Accountant and Lawyer, specialist in Strategic Tax Planning at OSP. Over 30 years of experience in tax optimization and asset protection.
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