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06 October 2025

Brazil: Treasury and IRS Lead PTI‑PRJ Phase

In brief

On 30 September 2025, PGFN/RFB Joint Ordinance No. 19/2025 was published. This ordinance deals with the second phase of the transaction in the collection of judicialized credits of high economic impact. These credits are based on the Reasonable Recovery Potential of the Judicialized Credit (PRJ) of the Comprehensive Transaction Program (PTI). This PTI was established by MF Normative Ordinance No. 1,383, of 29 August 2024.

The new regulation has the following features:

  • The agreement now covers debts starting at BRL 25 million (~USD 4.3 million), lowered from the previous BRL 50 million minimum in phase one.
  • Registration of debts as active debt by the Federal Government is not obligatory; such debts may alternatively be registered with the Federal Revenue Service.

The application period for the program is from: 1 October 2025 to 29 December 2025.

More details

The main features of the ordinance are as follows:

PGFN/RFB Joint Ordinance No. 19/2025 (second phase of PTI-PRJ)
Which debts can be included in the agreement?

Debts that are registered or not as an active debt at the Federal Treasury Department (it can be handled by the Federal Treasury Department), since the debts fulfill the following status:

  1. They are being discussed in court (judicial lawsuit).
  2. The amount must be at least BRL 25 million (~USD 4.3 million).
  3. They are fully guaranteed or have a decision suspending enforceability.
Deadline for adhesion From 1 October 2025 to 29 December 2025.
Discounts and installments
Discount Installment

Maximum 65%

The discount cannot be applied to the principal amount.

 Up to 120 months, but social contributions only count for 60 of those months.
Factors considered in the PRJ

The following factors will be taken into consideration in determining the potential reduction of the debts:

  • The degree of uncertainty regarding the outcomes of legal proceedings.
  • The duration for which enforceability has been suspended has been determined by a court decision.
  • The potential success of legal strategies is a key consideration.
  • The financial implications of the legal proceedings, including the costs associated with the lawsuit and the collection process.
Additional benefits
  • Flexible payment options, including staggered installments and the option to make a down payment.
  • Flexible guidelines for replacing or releasing guarantees.

 

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