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On 19 March 2024, the Public Notice of Special Settlement Agreement No. 1/2024 was published, which provides for the opening of the Zero Litigation Program 2024, a new special settlement agreement for tax debts in administrative litigation within the scope of the IRS of Brazil, the value of which, per litigation, is up to BRL 50,000,000.00.
Discounts and payment terms will be determined according to the degree of recoverability of the debts.
The deadline for joining the Program is 1 April 2024 to 31 July 2024.
The main features of the Public Notice are as follows:
(** The classification is determined primarily by the taxpayer's ability to pay).
(**The classification is determined primarily by the taxpayer's ability to pay).
Up to 100% of interest, fines, and attorney's fees, subject to a limit of up to 65% of the total amount of each debt.
This option does not offer any discount.
Obs: In the case of the social contributions provided for in item I "a" and item II of art. 195 of the Federal Constitution, the periods referred to in item I above shall not exceed 55 months.
1 We will not deal here with the "small value settlement", whose target audience is limited to individuals, individual micro-entrepreneurs, micro-enterprises, or small businesses that have debts with a consolidated value of up to BRL 84,720.00.
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Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.
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