Notice No. 6/2026 – PGFN Publishes Notice on Tax Settlement for the Regularization of Outstanding Debts

The Office of the Attorney General of the National Treasury (Procuradoria-Geral da Fazenda Nacional, "PGFN") has published Notice No. 6/2026, which sets forth the conditions for taxpayers to adhere to the PGFN's tax settlement proposal for the regularization of debts of up to BRL 45 million enrolled in the Federal Government's outstanding tax debt registry.

Adherence to the settlement must be made through the Regularize portal by September 30, 2026.

Notice No. 6/2026 provides for four settlement modalities and covers debts enrolled in the Federal Government's outstanding tax debt registry, whether of a tax or non-tax nature, through March 3, 2026, except under the Small-Value Settlement modality, which covers debts enrolled through June 1, 2025.

To adhere, the taxpayer must include all eligible enrollments, except for those that are secured, subject to existing installment arrangements, already settled, or those whose enforceability has been suspended by court order.

However, taxpayers may combine different settlement modalities, namely:

1. Payment Capacity Settlement;
2. Settlement of Debts Deemed Irrecoverable;
3. Small-Value Settlement;
4. Settlement of Debts Secured by Surety Bond or Bank Guarantee.

The use of tax losses or negative calculation basis of CSLL for the discharge of the debts is not permitted, and adherence is barred for any taxpayer whose prior settlement has been terminated within the preceding two years.

A key point of attention is that adherence entails the automatic conversion of judicial deposits—already existing and linked to the debts included in the settlement—into definitive payment, such that the settlement conditions will apply only to the remaining balance of the debt.

Among the main benefits, we highlight:

• Possibility of paying the outstanding debt in up to 120 or 145 monthly installments, depending on the modality;
• Discount of up to 100% on interest, penalties, and statutory charges, subject to caps of 65%–70% depending on the taxpayer's profile and the applicable settlement modality;
• Down payment ranging from 5% to 6% of the total consolidated debt amount, which may be paid in up to 6 or 12 installments, depending on the settlement modality.

For further information regarding this alert, please contact our tax team at: TaxpartnersTC@mayerbrown.com.