Brazil: Public Notices on Tax Litigation Settlement Agreements | Insight

In brief

On 1 September 2025, two Public Notices of Settlement by Adhesion in Tax Litigation of Relevant Legal Controversy were published, as follows:

Public Notice No.58/2025: Covers debts related to non-cumulative PIS/COFINS (Social Integration Program/Contribution for the Financing of Social Security) on conditional discounts and bonuses received by businesses from industry and suppliers.
Public Notice No.59/2025: Covers debts related to Individual Income Tax (IRPF), social security contributions, and contributions to third parties on amounts from stock options, profit-sharing (PLR), and supplementary private pension programs.

The deadline to join is 29 December 2025.

The main features of the Notices are as follows:

Notice 58/2025

Notice 59/2025

Tax thesis covered

Covers debts related to non-cumulative PIS/COFINS on conditional discounts and bonuses received by businesses from industry and suppliers.

Discussions regarding amounts:

a. Earned in stock option plans offered by companies to their employees and directors;

b. Ais as profits sharing and company results – PLR; and,

c. Paid by employers for supplementary private pension plans.

Taxes to be settled

PIS and COFINS

Deadline to join

Until 29 December 2025

Possible reductions

Additional benefits

Use of Net Operating Loss (NOLs) to settle to 30% of the amount due in the transaction (in any of the discount options).
The NOLs may be your own and/or of an affiliated or controlled company.
The reduced amount in the transaction will not be taxed for IR/CSLL/PIS/COFINS purposes.

* * * * *

*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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