On June 24, 2025, the Office of the National Treasury Attorney-General (PGFN) published Ordinance PGFN/MF No. 1,359/2025, which amends the rules of the Integral Settlement Program (Programa de Transação Integral – PTI), significantly broadening its scope. The measure aims to reduce the volume of tax litigation and enable a comprehensive resolution of liabilities involving multiple credits and lawsuits, even those below the former threshold of BRL 50 million.
Key Changes
Previously, the PTI was limited to the negotiation of federal tax credits registered in the Union’s active debt portfolio with a value equal to or greater than BRL 50 million, provided they were judicially secured or had their enforceability suspended by court order. Under the new ordinance, the program now also allows for the inclusion of lower-value credits, provided they fall under one of the following scenarios:
- Credits under dispute in the same legal proceeding as a debt already registered and valued at BRL 50 million or more, even if not yet enrolled in the active debt registry;
- Credits arising from a similar factual and legal context—i.e., debts being challenged in separate lawsuits that address the same factual and legal issues as a case involving a credit of BRL 50 million or more.
Through this expansion, PGFN aims to facilitate the comprehensive regularization of tax liabilities, even when they involve multiple proceedings or various credits, thereby simplifying the settlement process for taxpayers and increasing the program’s attractiveness.
Modality: Reasonable Potential for Recovery (PRJ)
Participation in the program remains subject to an assessment of the Reasonable Potential for Recovery of Judicialized Credit (Potencial Razoável de Recuperação – PRJ). This model evaluates:
- The estimated duration of the judicial proceeding;
- The likelihood of success for the National Treasury;
- The costs associated with maintaining the litigation and with forced collection measures.
This analysis allows PGFN to offer individualized settlement terms, including discounts and extended payment periods, based on the risk and opportunity cost of continuing the litigation.
Deadline for Enrollment
Taxpayers interested in participating in the PRJ modality under the PTI must submit their proposals by July 31, 2025.
Final Considerations
The changes represent a significant opportunity for taxpayers involved in complex or interconnected disputes, even where individual claims fall below the previously required threshold. Enrollment in the PTI requires a tailored technical and legal analysis, including an assessment of the economic feasibility of the proposal and the risks involved. Should you have any questions, please contact our specialized tax litigation team.