The Attorney General’s Office of the National Treasury (PGFN) and the Federal Revenue today (3), in Brasília, a tax transaction notice to negotiate up to R$ 150 billion in credits disputed by the government and taxpayers.
The amount represents the sum of all tax credits in dispute involving two of the largest legal controversies in dispute with the Federal Revenue, which represents a large part (R$ 122 billion) of all administrative litigation in progress (R$ 1.7 trillion) . In this case, the disputes involve the consideration of expenses with goodwill on equity interests for the calculation of tax amortization.
Memberships will remain open until July 29. This is the second tax transaction notice launched with the objective that both taxpayers and the Public Power give up winning any legal dispute. The first public notice of the type was published in May of last year.
“What is being offered is what we really understand to be within the theses defended by the Federal Revenue, the National Treasury and the taxpayer. There was a need for composition”, said the special secretary of the Federal Revenue, Julio Cesar Vieira Gomes.
Legal Taxpayer Law
The tax transaction is one of the types of negotiation regulated by the Legal Taxpayer Law, approved in 2020. It is different from the Tax Recovery Program (Refis), being deeper in the analysis of each case, stressed the Attorney General of the National Treasury, Ricardo Soriano.
“In the tax transaction, we assess the taxpayer’s financial situation, and we provide differentiated treatment for those who prove they need this privileged treatment, that is, those who would not be able to pay their debts economically”, explained Soriano.
In its most successful modality, which allows the negotiation of tax credits registered in the Union’s active debt, more than R$ 260 billion were negotiated by the Revenue, the National Treasury and taxpayers, in one million contracts, from 2020 to April this year.
The current tax transaction notice, involving widespread and specific legal controversies, can be read at Official Diary of the Union of this to havetuesday (3).