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On 15 August 2025, the National Treasury Attorney's Office (PGFN) and the Brazilian Federal Revenue Service (RFB) published Notice No. 51/2025, establishing the action calendar for the second half of 2025 under the tax settlement program. This initiative is part of the Comprehensive Settlement Program (PTI), created by Normative Ordinance MF No. 1,383/2024.
The notice addresses highly relevant and legally controversial tax matters, offering special negotiation conditions and defined deadlines for adherence.
1. Corporate Income Tax (IRPJ)/Social Contribution on Net Income (CSLL) on capital gains from Bovespa demutualization
2. Social Integration Program Contribution (PIS)/Contribution for the Financing of Social Security (COFINS) on sale of shares received from Bovespa and BM&F demutualization
3. Non-retroactivity of the concept of "marketplace" (Law No. 14,395/2022) for Excise Tax on Manufactured Products (IPI) purposes
4. Transfer pricing using the Resale Price Less Profit (PRL) method (IN RFB No. 243/2002 and No. 1,312/2012)
1. Non-cumulative PIS/COFINS on conditional discounts and bonuses received by retail chains
2. Social security contributions on amounts paid as profit sharing
1. Rules for small-value settlement (end of Federal Active Debt Management Program (PGDAU) Notices No. 3/2025 and 11/2025)
2. Ordinance on the second phase of PTI for judicialized debts
Tax settlement notices aimed at resolving legal theses typically offer favorable conditions, such as discounts of up to 65% on the total amount of credits, and the possibility of using NOLs, as well as precatórios (court-ordered payments) to offset debts. Exact conditions, including eligibility criteria and payment methods, will depend on the publication of specific notices for each thesis.
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