On August 1st, 2014, the Brazilian Revenue Services and Office of Attorney-General of the National Treasury enacted the Joint Administrative Ruling PGFN/RFB No. 13/2014, which regulates the application of the Tax Debt Installment Program provided for by Law No. 11.941/2009, as amended by Law No 12.996/2014 and Provisional Measure No. 651/2014.

Pursuant to such Administrative Ruling, taxpayers apply for the payment of federal tax liabilities, which were overdue on December 31st, 2013, in a lump sum or installments. The application may be filed by August 25th, 2014. The relevant liabilities to be included in the Tax Debt Installment Program are those assessed or not, suspended or not, and enrolled or not for collection through tax foreclosure.

Discounts on interest and penalties on the overdue tax debts will vary in accordance with the payment method elected by the taxpayer. In addition, if the debts are paid in installments (limited to 180 installments), the Administrative Ruling determines that the taxpayer must make a down payment that can vary from 5% (five per cent) to 20% (twenty per cent) of the total liability, depending on the total amount included in the Tax Debt Installment Program.

It is also possible to offset the amounts corresponding to fines and interest with tax loss balances accrued by the taxpayer.