Joint Ordinance PGFN/RFB No. 19/2025 – Integral Settlement Program (PTI), PRJ Modality
On September 30, 2025, the Office of the Attorney General of the National Treasury (PGFN) and the Federal Revenue Service of Brazil (RFB) published Joint Ordinance No. 19/2025, inaugurating the second phase of the tax settlement program under the Reasonable Potential for Recovery of Judicialized Credit (PRJ) modality, within the scope of the Integral Settlement Program (PTI).
This new phase aims to promote the resolution of high-impact tax disputes, involving judicialized tax credits of significant value, fully guaranteed or with enforceability suspended by a court decision.
- Scope of Eligible Credits
- Minimum value: Credits of R$ 25 million or more may be included, reducing the threshold compared to the previous ordinance (which required R$ 50 million).
- Related proceedings: Even credits below this threshold may be negotiated if they are connected to cases sharing the same factual and legal background as the principal lawsuit meeting the R$ 25 million criterion.
- Nature of credits: They must be the subject of a lawsuit filed by the taxpayer challenging the legality or existence of the tax assessment.
- Settlement Terms
The new phase of the PRJ maintains parameters similar to those in the first stage, with some relevant updates:
- Discounts: up to 65% on ancillary amounts of the tax credit.
- Installment plan: payment in up to 120 monthly installments.
- Judicial deposits: possibility of conversion into payment of the settled debt.
- Precatórios (court-ordered payments) and liquid and certain credits: may be used to offset debts.
- Guarantees: allows for flexibility in substituting or releasing judicial guarantees, as well as staggered installment schedules.
- Criteria for Concession
The calculation of discounts and settlement conditions will be conducted exclusively by the PGFN, on a confidential and strategic basis, considering factors such as:
- degree of uncertainty in the judicial outcome;
- duration of the proceedings and of the suspension of enforceability;
- cost of administrative and judicial litigation;
- likelihood of success of the taxpayer’s arguments.
This assessment is performed on an individual basis, reinforcing the selective and strategic nature of the PRJ modality.
- Deadlines and Procedures
- Adhesion deadline: until December 29, 2025.
- Scope: applies to credits either enrolled or not enrolled in the federal active debt register, provided that the requirements of the ordinance are met.
- Economic Impact and Outlook
In the first phase of the PRJ (April to July 2025), the PGFN received approximately 80 applications, with an estimated R$ 14 billion in potential settlements. A single case alone resulted in an immediate inflow of R$ 400 million to the National Treasury.
With the threshold lowered to R$ 25 million, the government expects a broader level of participation, facilitating the recovery of disputed tax credits while offering taxpayers more secure and predictable solutions for high-value, high-risk tax disputes.
Recommendation
Taxpayers with ongoing disputes falling within the parameters of the new ordinance are advised to conduct a strategic review of their tax contingencies to assess the feasibility of joining the program by December 29, 2025.