Zero Litigation Program

Zero Litigation Program

Government announces debt installment program, called “Zero Litigation”. The measure aims to reduce the deficit of R$223 billion.

Discover the payment options for the Zero Litigation program

Zero Litigation Program provides discounts for renegotiating tax debts and eliminating fines for companies. Find out the special conditions for your company when paying taxes with the Federal Revenue Service.

Who will benefit from Zero Litigation?

• Individuals and companies with tax debts under discussion within the scope of the Federal Revenue Judgment Offices, the Administrative Council for Tax Appeals (CARF) or debts in administrative litigation or registered in active debt of the Union.

Modalities

Tax credits in Administrative Tax Litigation:

1. Irrecoverable or Difficult to Recover: “No Entry”

• • Reduction of up to 100% in the value of interest and fines, observing the limit of up to 65% on the total value of each credit subject to negotiation, with a minimum payment of 30% of the outstanding balance in up to 09 installments and the remainder of 70% using credits resulting from tax losses and negative CSLL calculation basis.

1. High or Medium Recovery Outlook: “No Entry”

• • If classified as such, payment of at least 48% of the consolidated value of transacted credits (up to 09 installments) (without discount/reduction) and the remainder with the use of credits arising from tax losses and negative CSLL calculation basis (52 %).

1. Tax debts with an appeal pending judgment under the DRJ or CARF “With Entry”

• • Input equivalent to 4% of the value of credits transacted in up to 04 installments;
  • Remainder paid with a reduction of up to 100% in the value of interest and fines, observing the limit of up to: 65% of the total value of each credit in up to 2 installments or 50% of the total value of each credit in up to 8 installments.

Deadline

• From 8am on February 1, 2023 until 7pm on March 31, 2023.

Membership

• By opening a digital process on the e-CAC portal.

Tax advice – Dispute Settlement

• It is very important that companies have good tax planning so that debt renegotiation does not become an even bigger problem in the future of your business;
• Advice on tax matters, formalization of transaction agreements and tax planning.

Documents for joining “Zero Litigation”

• Duly completed membership application available on e-CAC;
• Proof of payment of the initial installment;
• If applicable, certification issued by an accounting professional regarding the existence and regularity of credits arising from tax losses and negative CSLL calculation basis, in the form of a specific form available on e-CAC.

Competitive advantage

• Did you know that the Zero Litigation program will offer discounts for taxpayers to eliminate debts and reduce tax conflicts?
• Our tax team has extensive experience in mapping public debts and advises companies from different sectors in resolving tax conflicts and closing disputes with the Federal Government;
• We advise companies in understanding the tax burden, presenting data and analyzes that contribute to decision-making and assessment of the best economic scenario.