On April 7, 2025, the Brazilian National Treasury Attorney’s Office (PGFN)\u00b9 published Ordinance No. 721\/2025, regulating one of the modalities under the Comprehensive Transaction Program (PTI)\u00b2, focusing on the settlement of high-impact judicial tax debts through the Reasonable Recovery Potential of Judicial Credit (PRJ)\u00b3.<\/p>\n
The Comprehensive Transaction Program (PTI), established by Ministry of Finance Normative Ordinance No. 1,383\/2024 (published on August 29, 2024), aims to promote debt regularization and efficiently resolve disputes through consensus, comprising measures designed to reduce high-impact tax litigation in Brazil.<\/p>\n
The PTI is part of a series of initiatives planned by the Brazilian Ministry of Finance to boost tax collection. According to the 2025 Annual Budget Bill (PLOA)\u2074 submitted to the National Congress, the program is expected to generate BRL 30 billion in revenue.<\/p>\n
Under Ordinance No. 721\/2025, benefits granted to taxpayers will be based on the Reasonable Recovery Potential of Judicial Credit (PRJ), measured by PGFN through criteria such as the uncertainty level of judicial outcomes and the duration of these disputes.<\/p>\n
This new tax settlement opportunity is particularly relevant for large taxpayers with good financial health, as it allows debt negotiation from the perspective of judicial dispute opportunity costs, without being tied to their payment capacity (CAPAG)\u2075.<\/p>\n
Key features of the newly regulated program:<\/p>\n
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This new tax settlement opportunity benefits companies considered “good payers” based on their financial health, which typically don’t receive attractive discounts due to their high payment capacity (CAPAG).<\/p>\n
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The modality established by Ordinance PGFN\/MF No. 721\/2025 represents a paradigm shift, moving away from evaluating benefits primarily based on the taxpayer’s economic conditions and focusing on aspects related to the opportunity costs of judicial disputes.<\/p>\n
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\nExplanatory Notes:
\n\u00b9 PGFN: Brazil’s federal agency responsible for representing the National Treasury in tax-related matters
\n\u00b2 PTI: A comprehensive program for settling federal tax debts in Brazil
\n\u00b3 PRJ: A metric used to evaluate the likelihood of credit recovery in judicial cases
\n\u2074 PLOA: Brazil’s annual federal budget proposal
\n\u2075 CAPAG: Payment Capacity Assessment, a metric used by Brazilian authorities
\n\u2076 Federal Court Orders (Precat\u00f3rios): Government-issued debt instruments resulting from final court decisions
\n\u2077 CSLL: Social Contribution on Net Profit, a Brazilian federal tax<\/p>\n","protected":false},"featured_media":12248,"template":"","categories":[82],"class_list":["post-12250","publicacoes","type-publicacoes","status-publish","has-post-thumbnail","hentry","category-notes"],"acf":[],"yoast_head":"\n