Created by Law 13,988/2020, Tax Settlement allows taxpayers negotiate tax liabilities, resolve disputes with the tax authorities, and reach faster, more predictable outcomes. Its use at the Brazilian Federal Revenue Service (RFB) has expanded in recent years; according to the 2025 “PGFN in Numbers” report from the Office of the Attorney General of the National Treasury (PGFN), settlements now exceed BRL 60 billion – evidence that the tool reshapes how controversies are resolved.

Today, two Public Notices stand out for taxpayers and companies with disputed liabilities:

• RFB Public Notice 05/2025: covers debts under administrative dispute; offers discounts of up to 65 percent on fines and interest; allows payment in up to 120 monthly installments; and permits the use of tax loss carryforwards or negative CSLL base credits to offset up to 70 percent of the outstanding balance.
• RFB Public Notice 04/2025: targets small-value debts and provides simplified rules with less bureaucracy and shorter deadlines. For tailored solutions, taxpayers may also pursue an individual settlement, by negotiating directly with the RFB.

Beyond reducing the tax burden, these settlements can stabilize cash flow, reduce risk, and improve relations with the tax administration. The trade-off: taxpayers must withdraw related lawsuits or administrative appeals and keep all obligations current, or the benefits may be revoked.

Tax Settlement has been gaining ground as a modern fiscal policy aligned with compliance practices and alternative dispute resolution (ADR) mechanisms. In a competitive business environment, where tax efficiency can be a strategic differentiator, it may be decisive for restructuring debt and strengthening corporate governance.

Conduct a careful assessment: gauge prospects in ongoing administrative litigation, review the Public Notices, and, where appropriate, pursue an individual proposal. Ultimately, this is a strategic decision that shapes risk management and the company’s posture before the tax authorities.