Taxpayers who owe the Union gained two more months to renegotiate the debt. The Tax Litigation Reduction Program, also known as Litigation Zero, had its membership deadline extended to 7 pm on May 31. The original deadline would end this Friday (31).
The postponement consists of a joint ordinance of the Federal Revenue and the Attorney General of the National Treasury (PGFN) published in an extraordinary edition of the Official Gazette.
In a note, the Federal Revenue reported that the postponement was requested by entities in the accounting sector. In addition to the Federal Accounting Council (CFC), the National Federation of Accounting Services Companies and Advice, Expertise, Information and Research Companies (Fenacon) and the Independent Audit Institute of Brazil (Ibracon) claimed the extension.
A program that extends to the Federal Revenue the model of tax transactions available since 2020 to the Attorney General of the National Treasury (PGFN), Litígio Zero allows the renegotiation of tax debts based on the taxpayer’s ability to pay, in exchange for the withdrawal of actions in the Justice (in the case of debts registered in the Active Debt of the Union) or administrative disputes at the Administrative Council of Tax Appeals (Carf), a body that judges debts with the Tax Authorities at the administrative level.
Membership can be requested through digital process at the Federal Revenue’s Virtual Service Center (e-CAC). Access to the e-CAC requires a silver or gold level account on the Gov.br Portal, digital certification (in the case of companies) or a special code that can be obtained using the receipt number of the last income tax return (for individuals ).
Announced in January by the Minister of Finance, Fernando Haddad, as one of the measures to recompose the government’s cash , Litigation Zero provides for the renegotiation of debts with the Union under special conditions. Admissions began on February 1st.
Although the program works in a similar way to the traditional Refis, there is a difference because discounts will be granted based on the size of the debt and the type of taxpayer. Debts – considered credits from the government’s point of view – will be classified based on how easily they can be recovered by the Union, as follows: type A credits (with a high prospect of recovery); type B credits (with average prospect of recovery); type C credits (hard to recover); or type D credits (irrecoverable).
discounts
Individuals, micro and small companies with debts below 60 minimum wages will be able to obtain discounts of 40% to 50% on the total amount of the debt, with a period of up to 12 months to pay.
For companies that owe more than 60 minimum wages, there will be a discount of up to 100% on fines and interest for debts considered irrecoverable and difficult to recover. These legal entities will also be able to use losses from previous years to write off 52% to 70% of the debt.
Whichever payment method is chosen, the minimum installment amount will be BRL 100 for an individual, BRL 300 for a micro or small business, and BRL 500 for a legal entity. The number of installments must adjust to the amount of the debit included in the transaction.
Litigation Zero also provides for the end of ex-officio resources within Carf for amounts below R$ 15 million. In these cases, when the taxpayer wins in the first instance, the Federal Revenue Service will no longer appeal, ending the dispute. According to the Ministry of Finance, the measure will extinguish almost a thousand processes in Carf, in the total amount of R$ 6 billion, and will help to relieve the agency for the judgment of large debts.
The Federal Revenue has prepared a guide to answer questions about Litigation Zero. More information about the program can be obtained here.
