Brazil: The Federal Treasury Department and Internal Revenue Services have published public notices for special settlement agreement of tax debts in litigation

In brief

On 1 September 2025, two Public Notices of Settlement by Adhesion in Tax Litigation of Relevant Legal Controversy were published, as follows:

  1. Public Notice No.58/2025: Covers debts related to non-cumulative PIS/COFINS (Social Integration Program/Contribution for the Financing of Social Security) on conditional discounts and bonuses received by businesses from industry and suppliers.
  2. Public Notice No.59/2025: Covers debts related to Individual Income Tax (IRPF), social security contributions, and contributions to third parties on amounts from stock options, profit-sharing (PLR), and supplementary private pension programs.

The deadline to join is 29 December 2025.


Contents

More details

The main features of the Notices are as follows:

  Notice 58/2025 Notice 59/2025
Tax thesis covered Covers debts related to non-cumulative PIS/COFINS on conditional discounts and bonuses received by businesses from industry and suppliers.

Discussions regarding amounts:

  1. Earned in stock option plans offered by companies to their employees and directors;
  2. Ais as profits sharing and company results – PLR; and,
  3. Paid by employers for supplementary private pension plans.
Taxes to be settled PIS and COFINS
  • Individual Income Tax (IRPF).
  • Social Security Contribution.
  • Contributions to Third Parties (other entities and funds), handled by IRS.
Deadline to join Until 29 December 2025

Possible reductions

  Option 1 Option 2 Option 3 Option 4 Option 5
Discount 65% 55% 45% 35% 25%
Minimum first payment 30% 25% 20% 15% 10%
Monthly installments Up to 12 Up to 24 Up to 36 Up to 48 Up to 60
Additional benefits
  • Use of Net Operating Loss (NOLs) to settle to 30% of the amount due in the transaction (in any of the discount options).
  • The NOLs may be your own and/or of an affiliated or controlled company.
  • The reduced amount in the transaction will not be taxed for IR/CSLL/PIS/COFINS purposes.

 

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