HIGHLIGHTS

New public notices issued for tax debt settlement arrangements

Offers allow for the negotiation of overdue tax liabilities, debts from investment subsidies, and platform or vessel charter agreements

In a joint effort, the Brazilian Federal Revenue Service (RFB) and the National Treasury Attorney General's Office (PGFN) issued three public notices in May, inviting applications for new tax debt settlement arrangements.

One of the offers allows for the negotiation of credits of up to BRL 45 million that have been registered as Overdue Federal Tax Liabilities, even if tax enforcement procedures are underway. The other two notices address more specific situations, involving the settlement of debts due to improper write-offs from investment subsidies and debts arising from platform or vessel charter agreements, respectively. Check out below.

Notice No. 2/2024: Settlement of Debts Up to BRL 45 Million Registered as Overdue Tax Liabilities
Eligible debts	Federal debts registered as Overdue Tax Liabilities not exceeding BRL 45 million, including those undergoing tax foreclosure or enforcement procedures, or those pertaining to terminated installment agreements.
Payment terms	Possibility of installment payments, with or without extension of the ordinary 60-month term: Down payment: 6% of the consolidated debt in up to 6 successive monthly installments. Remaining amount payable in up to 114 installments. Up to 100% discount on interest, fines, and legal charges (capped at 65% of the total debt). Irrecoverable and doubtful debts: remaining amount payable in up to 108 installments.
Other arrangements	Settlement of small claims (applicable to individual taxpayers, micro-enterprises, and small businesses). Settlement of liabilities secured by performance bonds or letters of guarantee.
Installment plan	Minimum monthly payment: BRL 100 (BRL 25 for Sole Microentrepreneurs - MEI) Interest is adjusted by the monthly accrued Selic rate, plus an additional 1%
Deadline for applications	7 PM on August 30, 2024
System for filing requests	REGULARIZE Portal

Notice No. 4/2024: Settlement of Tax Liabilities from Investment Subsidies

Eligible debts

Debts arising from the irregular write-off of tax breaks and ICMS-related benefits from the IRPJ/CSLL tax base, performed in violation of Article 30 of Law No. 12,973/2014, along with the corresponding fines.

Payment terms

Condition 1: Deduction of 80% of the consolidated debt, payable in12 monthly installments.

Condition 2: Payment of at least 5% of the debt (without deductions):

Deduction of 50% of the remaining amount, payable in 60 monthly installments; or
Deduction of 35% of the remaining amount, payable in 84 monthly installments.

Installment plan

Minimum monthly payment: BRL 500.

Interest is adjusted by the monthly accrued Selic rate, plus an additional 1%.

Deadline for applications

7 PM on June 28, 2024

System for filing requests

For Federal Revenue Service debts: e-CAC Portal

For PGFN debts: REGULARIZE Portal

Notice No. 6/2024: Settlement of Debts Arising from Vessel/Platform Charter Agreements

Eligible debts

Debts arising from IRRF, CIDE, and PIS/Cofins on remittances abroad related to vessel or platform chartering contracts, along with the corresponding fines.

Payment terms

Condition 1: Once the deposits are automatically converted into payment, a 65% discount is applied to the total debt. Tax loss carryforwards from Corporate Income Tax (IRPJ) and Social Contribution on Net Income (CSLL) are then used to pay the outstanding amount, with the remainder to be settled under the following conditions:

A minimum down payment of 30%; and
Remaining balance payable in up to 6 monthly installments.

Condition 2: A 35% discount on the debt amount, with the option to use tax loss carryforwards (IRPJ and CSLL) for payment. The remaining amount can be settled as follow:

A minimum down payment of 10% after the discount has been applied; and
Remaining balance payable in up to 24 monthly installments.

Installment plan

Minimum monthly payment: BRL 500.

Interest is adjusted by the monthly accrued Selic rate, plus an additional 1%.

Deadline for applications

7 PM on July 28, 2024

System for filing requests

For Federal Revenue Service debts: e-CAC Portal

For PGFN debts: REGULARIZE Portal

Specialized support

Domingues e Pinho Contadores provides specialized assistance for companies seeking to negotiate installment payment terms for their tax debts, ensuring full compliance with the tax authorities. You can count on our support: dpc@dpc.com.br.

How can DPC help your company?

Domingues e Pinho Contadores has a specialized team ready to assist your company.
Contact us at dpc@dpc.com.br

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New public notices issued for tax debt settlement arrangements

Rio de Janeiro

Av. Rio Branco 311, 4º e 10º andar - Centro
CEP 20040-903 | Tel: +55 (21) 3231-3700

São Paulo

Rua do Paraíso 45, 4º andar - Paraíso
CEP 04103-000 | Tel: +55 (11) 3330-3330

Macaé

Rua Teixeira de Gouveia 989, sala 302 - Centro
CEP 27910-110 | Tel: +55 (21) 3231-3700/p>

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