Brazil: Federal Revenue publishes rules on judicial deposits and tax settlements

In brief

On 7 July 2025, two ordinances were published that directly impact tax litigation:

  • Ordinance MF No. 1,430/2025 regulates judicial and administrative deposits involving the Federal Government. Starting 1 January 2026, deposits will be adjusted by the IPCA (Broad Consumer Price Index). Deposits made until 31 December 2025, will continue to be updated by the Selic rate.
  • Ordinance RFB No. 555/2025 repeals Ordinance RFB No. 247/2022 and introduces new regulations for the settlement of tax credits in administrative tax litigation, expanding the types of settlements, benefits, and negotiation criteria.

Contents

More details

Ordinance MF No. 1,430/2025 – Federal deposits
Interest rate

Deposits from 01/01/2026: updated by IPCA.

Deposits until 12/31/2025: remain updated by Selic.

Involved institutions

Deposits must be made exclusively at Caixa Econômica Federal.

Funds will be transferred to the National Treasury Account, as it occurs nowadays.

Mandatory instrument Use of the Judicial or Extrajudicial Deposit Document (DJE), generated electronically.
Effective date 1 January 2026.

 

Ordinance RFB No. 555/2025 – Tax credit settlement
Settlement types Adhesion, individual, and simplified individual.
Benefits for small taxpayers Up to 70% reduction and payment terms of up to 145 months.
Use of tax credits Allows use of tax loss carryforwards and negative CSLL base to settle up to 70% of the remaining balance.
Termination and appeal rules Specifies grounds for termination, right to appeal, and suspensive effect on appeals.
Transparency and digitalization Adhesion exclusively via e-CAC; publication of notices with objective criteria.
Suspension of deadlines and effects during review

Proposal submission suspends administrative proceedings related to included credits.

Procedural deadlines may be suspended in administrative tax litigation if agreed upon by the parties.

 

We remain available for any questions or clarifications.

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