Brazil: Sao Paulo introduces New Tax Settlement | Insight

In brief

On 8 September 2025, Notice PGE/TR No. 1/2025 was published, establishing the Special Settlement Program in the State of Sao Paulo (known as Programa Acordo Paulista). This program aims to facilitate the regularization of debts related to ICMS (VAT), ITCMD (Tax on Transmission of Property Causa Mortis and Donations), IPVA (Tax on Motor Vehicles), and fines imposed by Procon (the Department for Consumer Protection and Defense).

These debts must be registered as overdue liability certificates at the State Treasury in São Paulo.

The program offers favorable conditions, including discounts on interest and fines (except for debts classified as recoverable, which are not eligible for discounts), payment in up to 120 installments, and alternative options for settling debts, such as the use of VAT credits.

The deadline for joining is from 8 September 2025 to 27 February 2026.

More details

The main features of the Notices are as follows:

Acordo Paulista Program 2025

Which debts can be included in the agreement?

Debts registered as overdue liability certificates regarding ICMS, IPVA, ITCMD, and fines imposed by Procon.

Deadline

From 8 September 2025 to 27 February 2026.

Possible discounts

Degree of recoverability	Irrecoverable debts	Debts difficult to recover	Recoverable debts
Discount on interest and fines (Principal not included)	Up to 75%	Up to 60%	0%

Additional benefits

Installment plans of up to 120 months.
Possibility of using judicial deposits to reduce the outstanding debt.
Possibility of using accumulated ICMS credits (either own or acquired from third parties), limited to 75% of the total debt amount and applicable only to ICMS-related debts.
Possibility of using precatórios (court-ordered debt payments) recognized by the State, also limited to 75% of the total debt amount.
Possibility of canceling protests against securities after payment of the first installment.

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

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