Brazilian Federal Revenue Office and National Treasury Attorney-General’s Office (PGFN) sign a public notice acceding to the agreement of tax litigation transaction

The agreement allows debts to be paid at a discount of up to 50%.

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Brazilian Federal Revenue Office and National Treasury Attorney-General's Office (PGFN) sign a public notice acceding to the agreement of tax litigation transaction


The agreement allows debts to be paid at a discount of up to 50%


The Brazilian Federal Revenue Office and National Treasury Attorney-General's Office (Procuradoria-Geral da fazenda Nacional - PGFN) signed a new public notice that allows taxpayers to accede to the agreement of tax litigation transaction to close administrative or judicial discussions.

As a result, individuals and legal entities have the opportunity to end disputes against the Federal Government, guaranteeing the principle of legal certainty.

The agreement allows debts to be paid at a discount of up to 50% and is aimed at taxpayers who have lawsuits on trial, related to application of social security contributions levied upon profit sharing (Participação nos Lucros e Resultados - PLR), paid to other entities and funds for non-compliance with Act No. 10,101/2000.

Accession to the process can be made from June 1 to August 31, 2021 onward.


    Debits before the Brazilian Federal Revenue Office

    Adhesion must be made through the Virtual Service Center of Federal Revenue System (e-CAC).


    Debits registered at the Federal Registry of Defaulter Taxpayers

    Adhesion must be made through the REGULARIZE system, available on the PGFN website.

Payment methods


The taxpayer can choose the following payment methods:


  • 5% down payment of the total amount, no reductions for up to 5 installments, the remainder being paid in 7 months, with a 50% reduction on the principal amount, fines, interests, and other charges.
  • 5% down payment of the total amount, no reductions for up to 5 installments, the remainder being paid in 31 months, with a 40% reduction on the principal amount, fines, interests and other charges.
  • 5% down payment of the total amount, no reductions for up to 5 installments, the remainder being paid in 55 months, with a 30% reduction on the principal amount, fines, interests and other charges.

The minimum amount of the installment, whatever the method, will be 100 BRL for individuals and 500 BRL for legal entities.

As a condition for adhesion, taxpayers must point out all debts under administrative or judicial discussion related to the same topic (PLR for employees or for CEOs) calling off the respective administrative claims and lawsuits.


Specialized tax support


Domingues e Pinho Contadores tax team is able to set process adhesion, helping on the negotiation of installments and monitoring the process.


Cristiano Gonçalves, partner at Domingues e Pinho Contadores.

Contato: cristianogoncalves@dpc.com.br | + 55 21 3231-3700



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