The Federal Government of Brazil, through the Federal Revenue Service (Receita Federal) and the Attorney General’s Office for the National Treasury (PGFN), announced on July 11, 2025, the collection of R$ 10.2 billion as a result of the first cycle of tax transactions targeting large taxpayers. This measure, which is part of the tax reconciliation program promoted by the Ministry of Finance, represents a significant step in the efforts to achieve the fiscal balance projected for the current fiscal year.
The collection comes from the adherence of large companies to a dispute resolution model that allows tax disputes to be settled through advance payment of part of the debt and negotiation of the remaining balance. Of the R$ 10.2 billion collected, R$ 7.6 billion was paid in cash, while the rest will be paid in installments as stipulated in the agreements. The total amount renegotiated reaches R$ 24.4 billion, including debts in the administrative phase (R$ 14.4 billion) and others already registered as active debt (R$ 10 billion).
A key tool for fiscal consolidation
The conciliation strategy adopted by the federal administration not only reduces litigation but also provides predictability and immediate liquidity to the State. It is a legal mechanism provided for in Brazilian law that seeks to resolve relevant tax disputes quickly and efficiently, reducing judicial costs and avoiding delays in the enforcement of tax credits.
This policy is part of the Ministry of Finance’s effort to meet the goal of zero fiscal deficit by 2025, one of the priorities of the current economic team. The PGFN and the Federal Revenue Service have confirmed that at least three new transaction notices will be published in July, covering other disputes with a significant impact on tax collection.
Profile of resolved disputes
The most recent edict specifically addressed the so-called internal capital gains thesis (ágio interno), related to corporate reorganization within economic groups. It also included disputes over profit sharing (PLR) and private pension plans offered to senior executives in the financial system, issues that have historically generated a high level of litigation.
According to the PGFN, more than 60% of the amount collected came from cases related to these three lines of discussion. This demonstrates the success of the initiative in attracting relevant taxpayers with significant debts and in resolving complex disputes that, in many cases, had been pending for years without a final resolution.
Interrelation with transfer pricing
Although this first cycle of tax reconciliation has focused on specific disputes, such as internally generated capital gains (ágio interno), the Federal Revenue Service has confirmed that future edicts will include disputes directly related to transfer pricing. In Brazil, this area has become increasingly important since the adoption of new regulations aligned with OECD guidelines, especially after the 2023 reform.
Many of the ongoing disputes involve tax adjustments arising from transactions between related parties, in which the authority questions the reasonableness of the margins applied, the choice of methods, or the validity of the comparables used. Future transactions could represent an efficient way to resolve such disputes in advance, before they escalate to the courts.
Therefore, the experience gained in this initial process lays the groundwork for the use of tax transactions to be extended in the short term to the area of transfer pricing, a technical area that has historically been the subject of protracted disputes between taxpayers and the tax administration.
Outlook and next steps
The Brazilian tax administration has reiterated its commitment to expanding the use of tax transactions as a priority mechanism for resolving tax disputes. In this context, the new edicts are expected to address additional issues, allowing more taxpayers to regularize their situation through customized agreements based on criteria of economic reasonableness and ability to pay.
The transparency and efficiency of the process, coupled with the incentive of discounts on fines and interest for those who voluntarily participate, are pillars of the model implemented. The results obtained in this first stage reinforce the idea that tax transactions are becoming an effective tool in modern state administration, with positive impacts on both tax collection and the relationship between the tax authorities and taxpayers.
Source: Brasil247