On September 8, 2025, the Government of the State of São Paulo published Notice PGE/Transação No. 1/2025, within the scope of the “Acordo Paulista” program, which governs the negotiation of debts enrolled in the state’s overdue tax registry (dívida ativa). The initiative encompasses relevant state taxes, such as ICMS, IPVA, and ITCMD, as well as fines imposed by Procon, and offers differentiated conditions for settlement, including discounts of up to 75% on interest and penalties, extended installment plans, and the possibility of offsetting with compensatory credits.
Key Conditions
- Beneficiaries: taxpayers with state debts registered as dívida ativa up to the date of publication of the notice.
- Covered Taxes: ICMS, IPVA, and ITCMD, in addition to Procon fines.
- Adhesion Period: until February 27, 2026.
- Recoverability Criteria: the discount percentage varies according to the classification of the debt:
- Unrecoverable debts: up to 75% discount on interest and penalties;
- Hard-to-recover debts: up to 60% discount;
- Recoverable debts: no discount granted.
- Concession Limit: benefits may not exceed 65% of the total amount of the debt and do not affect the principal amount.
- Installment Plan: up to 120 months, without down payment, with the possibility of using court-ordered government bonds (precatórios) and accumulated ICMS credits for reduction of the outstanding balance.
- Guarantees:
- Recoverable debts in up to 84 installments are exempt from guarantees;
- For more than 84 installments, surety bond, bank guarantee, or real estate collateral will be required;
- For hard-to-recover or unrecoverable debts, no guarantee will be required, except when already existing in judicial proceedings.
Practical Considerations
The notice represents a strategic opportunity for both companies and individuals to regularize state tax liabilities under advantageous conditions, particularly with respect to debts classified as hard-to-recover or unrecoverable. The possibility of offsetting with ICMS credits and precatórios further enhances the program’s attractiveness, while the extended installment options ensure greater financial predictability.
It is advisable for taxpayers to carefully assess the classification of their debts, the impact on cash flow, and the feasibility of utilizing tax credits and precatórios before making a strategic decision regarding adherence.
Given the extended adhesion period (until 02/27/2026), taxpayers should proactively analyze their outstanding liabilities and develop a structured adherence plan to maximize the benefits available.