Public notice PGFN/RFB No. 53, published on August 14, 2025, is part of the PTI (Programa de Transação Integral – Comprehensive Transaction Program) initiative to resolve tax disputes in relevant and widespread controversies. Specifically, it addresses conflicts related to the application of the PRL (Preço de Revenda menos Lucro – Resale Price Less Profit) method for determining transfer prices, based on Article 18 of Law 9,430/1996 and Normative Instructions SRF No. 243/2002 and RFB No. 1,312/2012.
Subjects and Scope of the Transaction
Taxpayers facing tax debts-whether or not they are registered in the Union’s active debt-in administrative or judicial litigation may avail themselves of the mechanism if related to the application of the PRL method exclusively. Adherence to the transaction also implies the irrevocable waiver of appeals and allegations related to these debts, as well as the confession of the amount due.
Economic Benefits and Payment Terms
Regarding benefits, the public notice offers a staggered scheme of discounts and payment terms:
- Up to 65% discount, with a minimum initial payment of 30% and up to 12 installments.
- Alternatively, discounts of 55%, 45%, 35%, or 25%, depending on the initial payment and the number of installments, up to a maximum of 60.
In addition, it allows for an additional discount of up to 30% through tax credit compensation-IRPJ (Imposto de Renda da Pessoa Jurídica – Corporate Income Tax) tax losses or CSLL (Contribuição Social sobre Lucro Líquido – Social Contribution on Net Profits) negative base-provided that these derive from the fiscal year ending December 31, 2024.
Deadline and Procedure for Enrollment
The deadline for enrollment is November 28, 2025, at 7:00 p.m. (Brasília time). The joining terms depend on whether or not the debts are registered as active debt:
- For debts already registered: An enrollment through the PGFN’s Regularize portal.
- For those still in administrative litigation managed by the RFB (Receita Federal do Brasil – Federal Revenue of Brazil/IRS): An enrollment through e-CAC on the Receita Federal website.
Strategic Significance
- Alternative solution to extended litigation: It reduces risk and administrative burden for taxpayers and the tax authorities.
- Legal certainty: The program provides clear conditions and precedents for complex intra-group pricing disputes.
- Real financial relief: A Combination of discounts and the use of tax credits significantly improves companies’ liquidity.
Conclusion
Public notice PGFN/RFB No. 53/2025 represents a strategic opportunity for companies facing tax disputes over the application of the PRL method to Transfer Pricing. In short, with substantial benefits and high levels of legal certainty, this mechanism offers a viable and efficient alternative to traditional litigation.
Source: Governo Federal do Brasil – Diário Oficial da União