On 19 March 2024, the Public Notice of Special Settlement Agreement No. 1/2024 was published, which provides for the opening of the Zero Litigation Program 2024, a new special settlement agreement for tax debts in administrative litigation within the scope of the IRS of Brazil, the value of which, per litigation, is up to BRL 50,000,000.00.
Discounts and payment terms will be determined according to the degree of recoverability of the debts.
The deadline for joining the Program is 1 April 2024 to 31 July 2024.
Details
The main features of the Public Notice are as follows:
Deadline: from 1 April 2024 to 31 July 2024.
Eligible debts: debts under administrative review by the IRS, relating to taxes administered by the IRS, including the social contributions referred to in subparagraphs “a”, “b” and “c” of the sole paragraph of art. 11 of Law No. 8.212/1991, the contributions instituted by way of substitution and the contributions due by law to third parties and collected by means of DARF, the value of which, per dispute, is up to BRL 50,000,000.00.
1 We will not deal here with the “small value settlement”, whose target audience is limited to individuals, individual micro-entrepreneurs, micro-enterprises, or small businesses that have debts with a consolidated value of up to BRL 84,720.00.
Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.
Maria Rita Ferragut joined the Firm in 2019. With 25 years of experience, she is the lead partner of the Tax Law group, acting with a focus on Tax Litigation, at the federal, state and municipal levels. *Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.
Rafael Gregorin joined the Firm in 2002 and became partner in 2018. He integrates the tax practice group, with focus on litigation. Mr. Gregorin has a wide breadth of experience in tax and customs litigation, representing clients in disputes involving federal, state and municipal taxes.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.
Juliana Sampaio Lemos joined the Firm in 1998, in 2012 became Coordinator of the Judicial Litigation group and became partner in 2020. She is a specialist in legal proceedings and works in the Tax Litigation area, dedicating herself to conducting the proceedings from the time they are filed until the outcome in the higher courts. She also works in the Administrative Litigation area in the formulation of defenses, appeals and formal consultations with the bodies of the Public Tax Administration, at the Federal, State and Municipal levels. In tax practice, she also works in Tax Consulting with the elaboration of opinions on the application of tax rules and preventive consulting on tax procedures adopted in companies under Brazilian law.
Juliana Lemos has a wide breadth of experience in the elaboration of initial lawsuits, formulating thesis with the objective to obtain tax savings to the companies and resources at several spheres of the State and Federal Judiciary.
Juliana Lemos is a Legal Representative for Trench Rossi Watanabe’s clients in the most diverse areas, such as: industrial, pharmaceutical, technology, cinematographic, automotive, auto parts, services, tires, relocation of professionals, hospital, paper industry, tobacco exporter, toilet products, energy, foreign trade, technology information, sports, health, food and others.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.
