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On September 1, 2025, the Public Notices PGFN/RFB No. 58 and 59/2025 were published in the Official Gazette of the Union (DOU), authorizing taxpayers to join the settlement program for credits arising from tax litigation involving relevant and widespread legal controversies.
Public Notice No. 58 authorizes the settlement of tax disputes involving the levy of PIS/Pasep and COFINS on bonuses and conditional discounts received by retail trade in general from manufacturers and suppliers.
In its turn, Public Notice No. 59 offers an opportunity to regularize tax debts related to the levy of individual income tax (IRPF), social security contributions, and contributions to third parties on amounts related to stock option plans, profit sharing (PLR), and supplementary private pension plans.
Tax credits under administrative or judicial discussion, including penalties, can be included in the settlement, provided they are enrolled into overdue federal tax liabilities, subject to a lawsuit, motion to stay tax foreclosure, or an administrative appeal pending for decision. The deadline for formal adhesion is 7:00 PM on December 29, 2025.
Additionally, the Public Notices provide for different payment options and discounts ranging from 25% to 65%, depending on the number of installments and the down payment amount.
After the discount is applied, the taxpayer may also use tax loss credits from corporate income tax (IRPJ) and negative tax basis from social contribution on net profits (CSLL) to settle the remaining balance, up to a limit of 30%.
It is important to note that, as usual, the adhesion implies the irrevocable confession of the debt, waiver of appeals and objections, and compliance with a series of obligations and conditions, under penalty of rescission of the agreement and loss of the benefits.
This content was produced with the collaboration of law clerk Gabriela Brum.
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