New “Litigation Zero” Program Launched by the Federal Revenue Service


The Federal Revenue Service announced on March 19, the launch of the Adhesion Transaction Notice No. 1/2024, aiming for adherence to the resolution of administrative tax disputes through the “Litigation Zero 2024” program. This program is aimed at both individuals and legal entities with tax debts under discussion of up to R$ 50 million, provided they meet certain criteria specified in the notice.

The initiative allows for the negotiation of tax debts considered difficult to collect, offering the possibility of installment payments and the granting of discounts, with predefined maximum limits. Tax debts managed by the Federal Revenue, including social contributions from companies, contributions from domestic employers, and other legal contributions to third parties, are subject to negotiation under this notice.

To adhere to the transaction, interested parties must give up any disputes or administrative and judicial appeals related to the debts included in the negotiation, and must definitively and unquestionably admit the debt with the tax authorities. Adherence is conditioned on the payment of the first installment by the last business day of the enrollment month and compliance with the requirements listed in the notice.

The request for adherence to the program will be available from 8 a.m. on April 1, 2024, until 11:59 p.m. on July 31, 2024, through the digital process on the e-Cac Portal, specifically in the “Legislation and Process” section by the “Web Requests” service. Once the request is made, it suspends the progression of any related administrative fiscal processes until the analysis of the request is concluded. If the request is denied, it is possible to appeal administratively within a ten-day period after notification of the decision.

Furthermore, it is mandatory to communicate to the Federal Revenue before any disposal or encumbrance of assets, authorization for the compensation of amounts recognized by the agency, adherence and maintenance of the Electronic Tax Domicile (DTE), and for companies that are part of economic groups, the presentation of recognition of this condition along with the list of related parties.

Special payment conditions are available for debts classified as irrecoverable or difficult to collect, including significant reductions in interest, fines, and legal charges, in addition to options for extended installment plans. These conditions aim to facilitate tax regularization for taxpayers and promote administrative efficiency in the management of tax disputes.


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