Brazilian Internal Revenue Service Publishes New Rules for Low-Value Debts and Debts Up to BRL 50 Million

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On July 7, 2025, the Brazilian Internal Revenue Service (IRS) published Notices No. 4/2025 and No. 5/2025, introducing new modalities of tax settlement by adhesion within the scope of administrative tax litigation, with special conditions for taxpayers with low-value debts, or with debts up to BRL 50 million.

NOTICE NO. 4/2025 – LOW-VALUE DEBT SETTLEMENT

This notice applies to low-value tax credits that are under administrative litigation, aimed at individuals, micro-entrepreneurs (MEIs), individual employers, microenterprises and small companies, with debts of up to 60 times the minimum wages per case (equivalent to BRL 91,080.00 in 2025).

  • Discounts: Up to 50% of the total debt, regardless of the taxpayer’s payment capacity.
  • Installments: Up to 55 monthly payments.
  • Eligible debts: Federal and social security taxes, including third-party contributions, provided they are collected through the Document for the Collection of Federal Revenues (DARF).
  • Adhesion deadline: 8:59 p.m. on October 31, 2025, exclusively through the e-CAC portal.

NOTICE NO. 5/2025 – SETTLEMENT OF DEBTS UP TO BRL 50 MILLION

This applies to tax credits under administrative tax litigation, with a consolidated value of up to BRL 50 million.

  • Discounts: Up to 100% of interest, fines, and legal charges, limited to 65% of the total amount of each debt.
  • Installments: Up to 115 monthly payments, depending on the taxpayer’s payment capacity and the classification of the credit as irrecoverable or difficult to recover, pursuant to PGFN Ordinance No. 6,757/2022.
  • Special conditions: Applicable to specific taxpayers, such as individuals, MEIs, microenterprises, and small companies.
  • Adhesion deadline: 11:59 p.m. on October 31, 2025, exclusively through the e-CAC portal.

These new settlement modalities allow for tax regularization under favorable terms, especially for taxpayers with lower-value debts, or those facing financial difficulty.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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