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In brief

On 4 May 2021, the General Attorney’s Office of the Municipality of Rio de Janeiro enacted Resolution No. 1.052/2021, introducing a new amnesty program (“Resolve Rio“). The Resolve Rio program allows taxpayers to settle their debts with the Rio de Janeiro Municipality through reductions in interest, punitive fines and late payment fees of up to 60%.

As stated in the program, the Municipality of Rio de Janeiro will give priority to the settlement of debts under the following circumstances:

  1. remote chances of being enforced vis-à-vis evidence of the specific case files or given settled case law
  2. remote chances that an unfavorable decision against the Municipality will be overruled, especially if grounded on technical evidence
  3. if settlement was required to guarantee taxpayers the right of equal treatment
  4. in case of the taxpayer’s bankruptcy, a judicial recovery or liquidation
  5. if the specific facts and circumstances justify the debt’s review and settlement

Besides the situations listed above, taxpayers may settle other municipal tax debts under the program but must first submit a duly grounded application justifying the settlement benefit from a Municipal perspective.  

Resolve Rio allows taxpayers to enjoy:

  • up to a 60% reduction in interest, punitive fines and/or late payment fees, if the debt is settled in cash and on a lump sum;
  • up to a 40% reduction in interest, punitive fines and/or late payment fees, if the debt is settled in installments (up to 36 consecutive installments).    

To foster adherence to the Program, the “Resolve Rio” Regulation guarantees that negotiations carried out within the context of the Program will remain confidential and would not be used by the Municipality in future discussions.

Resolve Rio entered into full force and effect on 4 May 2021 and will be available for 90 days (i.e., until 2 August 2021).

Please do not hesitate to contact us if you require further information.

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*In cooperation with Trench Rossi Watanabe, a Brazilian law firm.


Maria Fernanda Furtado is a Principal in Baker McKenzie's Rio de Janeiro office.


Horácio Veiga de Almeida Neto joined the Firm in 2011 as a senior lawyer and became a partner in 2019. He integrates the tax & controversy practice group, of which he was part in his previous passage in the office between 2000 and 2003. Currently he leads the tax litigation practice group in the Rio de Janeiro office. He also deals with Customs Law Consultancy, related to the oil and gas industry, with emphasis on importation/exportation, tax customs regimes, charter agreements, etc.

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