
The São Paulo City Government announced, on November 1, 2025, a comprehensive municipal tax debt regularization program, offering discounts of up to 95% on interest and penalties applicable to IPTU and ISS (Service Tax) debts enrolled in active debt. Simultaneously, the City Council approved a bill revising the tax base and IPTU rates for fiscal year 2026, representing one of the most significant tax changes of the period for taxpayers and companies with properties located in the state capital.
The incentivized settlement program announced by the City Government seeks to recover tax credits accumulated in recent years, allowing substantial reduction of late payment charges. According to released information, discounts can reach up to 95% of interest and penalties, with installment payment options depending on the modality chosen by the taxpayer.
From a legal perspective, this is a simplified tax settlement that follows the national trend of encouraging fiscal self-composition—a movement reinforced by Law No. 14,375/2022 and PGFN Ordinance No. 1,241/2024. Although municipal rules have their own specificities, the rationale is the same: replace prolonged litigation with negotiated regularization through mutual concessions.
However, it is important to note that enrollment in programs of this nature typically implies waiver of any challenges, defenses, or lawsuits related to the included debts.
Therefore, the decision to enroll should be preceded by a thorough legal analysis—especially when there are disputes regarding the tax base, statute of limitations, lapse, or formal nullities in the constitution of the tax credit.