The recent publication of Technical Notes on the linkage between electronic tax documents (DF-e) and financial transactions represents a significant step in the implementation of the split payment model under Brazil’s Tax Reform.
Under this framework, the integration between invoicing and payment is now a mandatory requirement for the accurate calculation of tax liabilities and the proper recognition of input tax credits.
Taxpayers may establish this linkage through two mechanisms:
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Transmission of the invoice key to the payment service provider at the initiation of the transaction
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Reporting of transaction data within DF-e fields or through specific events
The Technical Notes primarily address the second mechanism, providing detailed guidance on how financial information must be embedded in fiscal documentation.
Implementation Timeline
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Testing Environment (Homologation)
Available from April 6, 2026 -
Production Environment (Go-Live)
Starting May 4, 2026
Key Actions to Take Now
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XML and System Adjustments
Invoicing processes must be updated to include financial transaction data, enabling the automatic withholding of IBS and CBS. -
Cash Flow Planning
Taxes will be segregated at the moment of payment, directly impacting working capital dynamics and liquidity management. -
Tax Credit Governance
Accurate linkage between payment and fiscal documents is essential to ensure compliance and secure input tax credits.
This development goes beyond regulatory compliance. It requires alignment between tax, finance, technology, and commercial teams, as well as a reassessment of traditional billing and settlement models.
Organisations that begin preparing now will be better positioned to manage risk, cost, and operational complexity in the new tax environment.
