The Office of the Attorney General of the National Treasury (PGFN)¹, through Legal Opinion SEI No. 1.199/2025, clarifying Notice No. 25/2024, has significantly expanded the scope of the tax settlement program for debts arising from internal goodwill², establishing a unique opportunity for business groups seeking legal certainty and predictability in regularizing sensitive tax liabilities. Below are the main benefits of the program:

• Expanded Debt Inclusion: now, in addition to tax assessment notices, tax debts arising from non-approved tax compensations can also be included, provided they are exclusively related to the tax amortization of internal goodwill.

• Substantial Discounts: the program offers discounts of up to 65% on the total debt amount, providing a significant reduction in tax liability.

• Use of Tax Losses: companies can use their own tax losses or those from related companies (parent companies, subsidiaries, or companies under common control) to settle part of the outstanding balance, subject to the limits of each category.

• Legal Certainty and Predictability: enrollment in the program requires withdrawal from all related litigation, whether judicial or administrative proceedings.

• Focus on Large Groups and Strategic Sectors: companies in the energy, infrastructure, telecommunications, financial, and retail sectors, especially those with a history of corporate reorganizations, will find in this program a distinctive solution for regularizing significant liabilities.

Exclusive and Temporary Nature

The internal goodwill tax settlement program is a one-time initiative with no plans for reopening the same theses in the future. The deadline for enrollment is June 30, 2025, making this the ideal time to reassess tax strategies and take advantage of exceptional regularization conditions.

This guidance reinforces the role of the Integral Transaction Program (PTI)³ as a priority tool of the Brazilian National Treasury for resolving strategic disputes with large taxpayers. As a result, companies with a history of corporate reorganizations, particularly in the energy, infrastructure, telecommunications, financial, and retail sectors, now have greater legal certainty and predictability to negotiate the regularization of sensitive tax liabilities.