International
Asia Pacific
EMEA
North America
Latin America
On 7 February 2024, the Sao Paulo State Attorney General's Office (PGE/SP) published Resolution No. 6/2024. The resolution regulates State Law No. 17,843/2023 on tax settlements. In addition, on 7 February 2024, PGE/SP also published the first call for adherence (PGE/SP Notice No. 1/2024) providing for the possibility to settle ICMS debts registered as an Active Debt of the State of São Paulo.
The settlement can be done by paying the debts in up to 120 installments and/or applying discounts of up to 100% on interest on late payments. This notice will be available until 29 April 2024.
PGE Resolution No. 6/2024 outlines the requirements for settlements for the collection of tax debts recorded as Active Debt of the State of São Paulo (and other state entities whose representation is the responsibility of the Attorney General's Office of the State of São Paulo). The main points regulated are those we have already covered in our Legal Alert on Law 17.843/20231.
Along with the Resolution, PGE/SP Notice No. 1/2024 was also published. The deadline to join program is from 2 July 2024 to 29 April 2024.
Below is the main information related to Notice No 1/2024:
ICMS debts that are registered as active debt and have default interest calculated based on State Laws No. 13,918/2009 or No 16,497/2017 can be included in this modality.
The below debts cannot be considered:
The total discounts cannot reduce the principal amount of the debt.
It is possible to settle up to 75% of the total debt value after discounts, using:
It will also be possible to use amounts that have been deposited, blocked, made unavailable or seized administratively or judicially, including to pay the 5% down payment of the residual value.
If payment is made in up to 60 installments, the guarantee will be waived, unless it has already been provided in the court proceedings.
For longer payment periods, a guarantee of the full debt will be required.
1 For more details on the legislation, click here to access our legal alert of 09/11/2023.
* * * * *
Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.
Copyright © 2025 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.
Are you sure want to delete comment ?
Scan this QR Code to share this content
