On 5 October 2026, the Brazilian Federal Revenue Service (Receita Federal) and the National Treasury Prosecutor’s Office (PGFN) jointly opened a special tax transaction (transação tributária) for debts arising from the substitute penalty for forfeiture (multa substitutiva da pena de perdimento). This measure allows taxpayers to settle such debts with discounts of up to 65% and the possibility of using tax losses (prejuízo fiscal) and negative CSLL bases to offset the amounts. The transaction is governed by specific ordinances and aims to reduce litigation, improve collection efficiency, and provide relief to taxpayers with customs-related penalties. Eligible debts must be registered in the system and meet the criteria established in the enabling legislation.
Key Takeaways
- Significant Discounts: Up to 65% reduction on principal, interest, and fines, making settlement financially attractive.
- Tax Loss Utilization: Companies with accumulated tax losses can offset them against these debts, improving cash flow.
- Customs Focus: The measure targets penalties from customs infractions where goods were not forfeited but a substitute fine was imposed.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement