The Federal Revenue Service and the Attorney General’s Office of the National Treasury (PGFN) have announced the opening of a new phase of tax transactions for January 2024 focused on the collection of Corporate Income Tax (IRPJ) and Social Contribution on Net Profits (CSLL) on the profits of the investing company domiciled in Brazil earned through its foreign investee.
The initiative aims to enable the regularization of some taxpayers and recover a portion of the R$69 billion that is the subject of disputes in administrative and judicial proceedings.
According to the text made available for public consultation, interested parties will have until June 28, 2024 to join this transaction, but there is already a work front underway to identify other tax theses that could be chosen for other future transactions.
The final terms of this agreement have not yet been released, but considering the current terms the transaction will offer discounts of up to:
- 65% of the principal amount, interest, fines and charges in the event of an installment payment of up to 6 months;
- 50% of the principal amount, interest, fines and charges in the case of installments of up to 18 months;
- 35% of the principal, interest, fines and charges in the case of installments of up to 30 months.
As mentioned, the longest installment plan possible is 30 months and in all cases an initial payment of 6% of the total debt will be required. The possibility of using tax losses to pay off debts is not completely ruled out, according to the undersecretaries.
If you have any questions on the subject, our tax team is available to answer them.
