On July 7, 2025, the Brazilian Internal Revenue Service (IRS) published Notices No. 4/2025 and No. 5/2025, introducing new modalities of tax settlement by adhesion within the scope of administrative tax litigation, with special conditions for taxpayers with low-value debts, or with debts up to BRL 50 million.
NOTICE NO. 4/2025 – LOW-VALUE DEBT SETTLEMENT
This notice applies to low-value tax credits that are under administrative litigation, aimed at individuals, micro-entrepreneurs (MEIs), individual employers, microenterprises and small companies, with debts of up to 60 times the minimum wages per case (equivalent to BRL 91,080.00 in 2025).
- Discounts: Up to 50% of the total debt, regardless of the taxpayer's payment capacity.
- Installments: Up to 55 monthly payments.
- Eligible debts: Federal and social security taxes, including third-party contributions, provided they are collected through the Document for the Collection of Federal Revenues (DARF).
- Adhesion deadline: 8:59 p.m. on October 31, 2025, exclusively through the e-CAC portal.
NOTICE NO. 5/2025 – SETTLEMENT OF DEBTS UP TO BRL 50 MILLION
This applies to tax credits under administrative tax litigation, with a consolidated value of up to BRL 50 million.
- Discounts: Up to 100% of interest, fines, and legal charges, limited to 65% of the total amount of each debt.
- Installments: Up to 115 monthly payments, depending on the taxpayer's payment capacity and the classification of the credit as irrecoverable or difficult to recover, pursuant to PGFN Ordinance No. 6,757/2022.
- Special conditions: Applicable to specific taxpayers, such as individuals, MEIs, microenterprises, and small companies.
- Adhesion deadline: 11:59 p.m. on October 31, 2025, exclusively through the e-CAC portal.
These new settlement modalities allow for tax regularization under favorable terms, especially for taxpayers with lower-value debts, or those facing financial difficulty.
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