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

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.

For more information on this newsletter, please contact our tax team.