Menu
Back

Federal Tax Settlement Program for Goodwill Deduction Liabilities

28/01/2025

On December 31, 2024, the Office of the Attorney General of the National Treasury (PGFN) issued Notice No. 25/2024, establishing a specific program for the negotiation of tax debts related to goodwill deduction. This program covers:

  • Internal goodwill: Deduction of goodwill within the same corporate group.
  • Goodwill generated by a vehicle company.

Adhesion Conditions

Adhesion deadline: Until 7:00 PM on June 30, 2025.

The settlement is available for taxpayers with debts registered as overdue tax liabilities, pending lawsuits, tax enforcement defenses, or administrative appeals awaiting final judgment.

Offered Benefits

  • Discounts: Up to 65% off the total debt amount, including principal, interest, and penalties.
  • Tax exemption: The granted discounts will not be subject to PIS, COFINS, IRPJ, or CSLL taxation.
  • Use of tax credits: Possibility to offset debts using IRPJ loss carryforwards and CSLL negative tax base from the taxpayer or controlling/affiliated companies (with a relationship established by 12/31/2024).

Installment Payment Options

The notice provides five installment plans with specific conditions:

  • Discounts ranging from 25% to 65%.
  • Monthly installments adjusted by the SELIC rate.
  • Minimum initial payment proportional to the outstanding balance.
  • Payment terms of up to 59 monthly installments.

 Requirements for Maintaining the Settlement

  • The taxpayer must remain up to date with FGTS and federal tax payments during the settlement period.
  • The agreement will be terminated if new debts are not settled within 90 days.

 Recommendations

 This program presents a valuable opportunity to settle tax liabilities under favorable conditions. However, it is essential to assess the feasibility of participation based on your financial situation and the terms outlined in the notice.

Contact our firm for a detailed analysis and guidance on the adhesion process!

NEWSLETTER

Stay updated on the latest news and bulletins in the tax and corporate sectors.

    By providing my data, I agree to the Privacy Policy.