Amendments to the Tax Settlement Agreement Law

On June 22, 2022 it was enacted Law No 14,375/2002, preceded by Provisional Measure No 1,090/2021, which, among other legal provisions, amended Law No 13,988/2020, that instituted the possibility of settlement of federal tax and non-tax debts (similar to the Offer in Compromise institute practiced by the US IRS).
 
The amendments to the presidential approval aim to expand the advantage that the Federal Revenue Service of Brazil and the National Treasury Attorney’s Office may grant to taxpayers upon the settlement of tax debts.
 
The Law has not been modified concerning the settlement agreement for debts related to relevant and widespread tax dispute or litigation (cases involving specific subject matter under dispute by several taxpayers). Therefore, the Public Notice No 09/2022, which addresses the tax settlement agreement for debts relating to goodwill (whose adhesion term will end on July 29, 2022), will not be affected by the amendments to the tax settlement agreement law.
 
Please find below a chart highlighting the main amendments to the tax settlement agreement law:

Please let us know if you need any further clarification.