The Brazilian Federal Revenue Service has issued Notice of Settlement 01/2024, reopening the “Zero Litigation” benefits program. With the program, individuals and companies can settle their tax debts with significant discounts on fines and interest.
The program is a facilitator in the quest to resolve disputes between taxpayers and the tax authorities, providing a more agile and efficient alternative in tax matters.
Now, taxpayers have the opportunity to negotiate their debts, provided they do not exceed R$50 million, with discounts and payment in installments, in exchange for a commitment to regularize their tax obligations.
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Deadline for joining and discounts
Adhesion to the program has been available since April 1 and is expected to end on July 31, 2024.
There is the possibility of a reduction of up to 100% of interest and fines, in the event of debts classified as irrecoverable or difficult to recover, with the limitation of the reduction being up to 65% of the value of the credit to be negotiated.
Payment methods
The taxpayer must pay a down payment of at least 10% of the total amount of the debt. This payment can be made in up to 5 installments and the remaining balance in up to 115 installments.
However, a global analysis of the amount owed is not enough, and an individualized technical assessment of each debt is recommended in order to classify them appropriately.
In some situations, the program also allows the use of credits from tax losses and negative CSLL calculation bases. In this case, a down payment of at least 10% of the total amount of the debt must be made in cash, and installments can be made in up to 5 installments. The balance remaining after the down payment can be paid 70% using these credits and 30% in up to 36 installments.
Criteria for joining
Joining the Zero Litigation Program has important specifics, and it is necessary to understand not only the requirements indicated in the public notice, but also the conditions and obligations for joining the settlement program.
An example of these obligations is the need to waive any administrative appeals or legal disputes over the debts being settled, in addition to notifying the Brazilian Federal Revenue Service about the sale or encumbrance of assets.
As you can see, the program is advantageous for resolving outstanding tax debts, but remember that adherence requires careful analysis of the conditions and obligations stipulated in the public notice, in order to achieve the best combination of benefits.
If you have any questions, our tax team is available to provide clarification and guidance on the Zero Litigation Program 2024.
