PGFN and Federal Revenue Service publish a new public notice for transactional agreements on tax disputes

Principal amounts, fines, interest rates and other charges may be reduced by up to 50%.

The Attorney General's Office of the National Treasury (PGFN) and the Federal Revenue Service of Brazil have published a new public notice allowing for transactional agreements on tax disputes. The measure, which grants benefits to taxpayers who wish to settle their debts, is the second such transaction carried out jointly by the public agencies.

The agreements are intended for taxpayers who have administrative proceedings or lawsuits under trial relating to the tax use of goodwill amortization expenses stemming from the acquisition of equity interests under the legal system in effect prior to Law No. 12,973/2014.

Application period

The period for application is May 2 - July 29, 2022.

Conditions for renegotiation

Tax debts, whether or not entered in the past-due liability roster (dívida ativa), can be subject to renegotiation.

Among the conditions set by the government to waive part of its claim, taxpayers are required to agree to drop their administrative proceedings and lawsuits, all of which must be indicated when filling the request.

All the requirements are listed in the public notice

Benefits

The minimum down payment is 5% of the total value of the selected entries – no discounts applied –, which may be paid in up to five monthly installments. The remaining payment may be divided into:

- up to 7 installments, with a 50% discount on principal amount, fines, interest rates and other charges; - up to 31 installments, with a 40% discount on principal amount, fines, interest rates and other charges; - up to 55 installments, with a 30% discount on principal amount, fines, interest rates and other charges.

How to apply

For debts entered in the Federal past-due liability roster (dívida ativa da União), applications must be submitted through the REGULARIZE portal.

For non-registered debts, submissions must be made by filing an electronic process through the e-CAC .

Expert tax support

The tax department at Domingues e Pinho Contadores is ready to put transaction agreements into practice, renegotiating payments of installments and monitoring the ensuing administrative proceeding. You can count on our support: dpc@dpc.com.br