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Brazilian Federal Revenue Service Opens Opportunity for Tax and Social Security Debt Settlement Until October 31, 2025

The Brazilian Federal Revenue Service has opened an opportunity for individuals and companies to reach an agreement to negotiate tax and social security debts currently under discussion in administrative proceedings .


This means that even before a case reaches court, it is possible to settle debts and obtain significant discounts.


Who Can Participate

  • Individuals (regular taxpayers).

  • Microentrepreneurs, micro and small businesses.

  • Companies of any size with debts under administrative dispute with the Federal Revenue.

  • Educational institutions, farmers, and cooperatives.

Debts can be up to R$ 50 million per case, and it is also possible to include small-value debts (up to 60 minimum wages per case), which receive even better conditions.


Main Benefits

  • In certain cases, up to 100% reduction in interest and fines.

  • For individuals, microentrepreneurs, micro and small businesses, educational institutions, agricultural businesses, or cooperatives, the reduction can reach 70% for debts classified as hard to recover.

  • Payment term: up to 145 monthly installments in special cases.

  • Possibility of using tax loss credits to reduce part of the debt (for companies).


How It Works for Social Security Debts

  • You must pay 5% of the total debt upfront.

  • You may use up to 30% of the remaining fines and interest with tax loss or negative CSLL base credits (for companies entitled to them).

  • The rest can be paid in up to 50 monthly installments.

Important: The down payment and the number of installments depend on the debt’s recovery classification. The Federal Revenue classifies debts according to the probability of collection: high, medium, difficult, or uncollectible. The lower the chance of collection, the greater the discounts and payment terms.

Deadline to Apply

Applications must be submitted by October 31, 2025, via the Federal Revenue’s electronic system (e-CAC). You will need to complete the online form and present required documents, such as the payment capacity certificate.


Why Seek Professional Guidance?

Every case has specific rules. Before applying, it is essential to check whether the government is still legally allowed to collect that amount from the taxpayer, because after a period of five years, the government can no longer collect the debt — provided there has been no interruption of this time limit. It is also important to verify whether the interest and fines charged are indeed valid and within the limits established by law. If they are not, signing a tax debt settlement agreement in Brazil means recognizing the debt, which makes it impossible to later dispute the amount charged by the government, even if it is higher than what the law allows — in other words, even if it is illegal.


Our office can review your case, check the legality of the charges, confirm whether the debt can still be collected, and ensure that any settlement is truly in your best interest.


💼 Tax Lawyer Clivanir Cassiano de Oliveira

Specialist in Public and Tax Law. Serves Brazilian and foreign taxpayers living or wishing to live in Brazil. Provides legal advice on avoiding double taxation based on international tax treaties with Brazil. Provides income tax exemption case for retirees and pensioners with serious illnesses.




 
 
 

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