Tax liabilities
The second blow
Settling the debt that arrived by letter is the easy part. The one that has not arrived yet is what brings the deal down.
The script repeats itself. The notice arrives, the company looks for a firm, the firm settles that debt, everybody celebrates, and three months later another one arrives. The certificate is still refused, the financing is still blocked, and it feels as though the money spent on the first settlement was thrown away. It was not thrown away: it was spent in the wrong order, on the wrong part of the problem.
Negotiating with the federal government is not an over-the-counter price: it is calibrated by the debtor's capacity to pay, assessed over the whole of their situation. Whoever settles on a single registered debt consumes cash and consumes capacity, and arrives at the second conversation in a worse position than before. The discount that existed for the whole does not come back.
There is a second effect, more mundane and more cruel: there is only one certificate. It is no use clearing the registered debt that produced the letter if a filing was never delivered, or a social security debt or a broken instalment plan was left out. The operation stays blocked, and the company finds that out on the eve of signing the contract.
The review has two sides, and they do not talk to each other on their own.
At the Receita Federal (the federal tax authority) sit the debts not yet registered for collection: administrative litigation under way, what was declared and not paid, offsets not approved, instalment plans active and broken, and the ancillary filings still missing, which on their own hold up a certificate.
At the Procuradoria (the federal treasury attorney's office) sits what has already become enrolled debt: registrations, tax enforcement actions, attachments, asset listings. It is a different yardstick, a different system and a different counterpart.
And there is what is not yet debt but is already on its way: defence deadlines running, assessment periods about to close, and the reverse of that, what can no longer be collected. This last point is the most forgotten of all.
Not everything that appears on the screen is still enforceable. The tax authorities have five years to assess the credit, on pain of lapse, and another five to collect it, on pain of limitation. In a tax enforcement action left standing with no assets or no debtor located, there also runs the intercurrent limitation of article 40 of Law 6,830/1980, whose counting the Superior Court of Justice settled in a repetitive-appeals ruling: the one-year suspension period starts automatically upon notice of the failure to locate, and the five-year period runs straight after, without depending on a judicial order.
Asking for that to be recognised before proposing a settlement moves the arithmetic to another place: negotiating an amount already time-barred is paying twice, because joining a settlement implies confessing the debt. Each case has its own date, and that is why the request is made one by one, with the timeline assembled, and not in a block.
Tax settlement, provided for in Law 13,988/2020 as worded by Law 14,375/2022, allows a reduction of up to 65% of the total value of the debt, a ceiling that rises to 70% when the debtor is an individual, a micro-enterprise, a small business, a cooperative, a civil society organisation or a Santa Casa (a charitable hospital). The term goes to 120 months, and to 145 months in those same cases.
A detail that changes the calculation and is almost never explained: the discount falls on interest, penalties and the statutory collection charge, and it can reach the whole of them, respecting that ceiling on the total. In an old debt, where the accessories already exceed the principal, that is what produces a reduction close to half. The principal is not forgiven, and whoever promises that is selling something that does not exist.
On the administrative litigation side, in July 2026 the Receita Federal opened Notices 9 and 10, for debts under dispute of up to R$ 50 million per case, with enrolment open until 30 October 2026. On the enrolled-debt side, the Procuradoria maintains Notice 6/2026, calibrated by capacity to pay.
Above R$ 1 million in enrolled debt, the conversation stops being enrolment in a notice and becomes an individual settlement: a proposal filed through the REGULARIZE portal, which a National Treasury attorney examines and on which they may counter-propose. Above R$ 10 million, the procedure is the full individual one. The basis is PGFN Ordinance 6,757/2022.
That is why the Procuradoria's table is worth more than the form's: there is someone there with room to assess the specific case. Except that this room does not open for whoever turns up with an incomplete spreadsheet. It opens for whoever presents the whole situation, with a consistent capacity-to-pay report, guarantees in proportion, and a request the attorney can defend internally. That is repertoire and a relationship built over time, not a form filled in a hurry.
First the complete inventory, on both sides, with what is falling due and what has already fallen. Then the removal of what is no longer enforceable, requested case by case. Next the classification of what is left by criticality and by effect on the certificate. Only then the negotiation, at the right table, and in the order in which one decision does not spoil the next.
The final product is not a settlement. It is the certificate, and the absence of a second blow.
We do not promise a discount on the principal, because the law does not allow it. We do not promise a term that capacity to pay cannot sustain, because a broken settlement is worse than an open debt: the discount is lost, credibility is lost, and you go back to the start with less cash. And we do not say how much can be recovered before looking at the data, because whoever says it is guessing.
Diagnosis with defined scope, timeline and price; every thesis classified by risk, in writing, before any decision of yours. Execution follows the administrative route, with a calculation trail and an audit trail, and remuneration falls on realised benefit.
Official sources, at the exact point: the article of law, the service or the search you can use today. None replaces analysis of the specific case, which is our work.
Each note starts from a sourced figure, explains the mechanism behind it and ends with a test you can run yourself, today, without calling us. They are deliberately short pieces: what does not fit in them fits in a conversation.
A note does not replace the review — it shows the mechanism and gives the reader back the ability to check alone. That is deliberate: whoever understands the mechanism negotiates better, including with us.
If the reading raises a question the note does not answer, it is probably the right question. Worth sending: answering a new question is the cheapest way to find out what we have not explained properly yet.
We do not promise a percentage before looking at the data, we do not promise a homologation date — the procedure belongs to the State: and we do not chase speculative theses to fatten an opinion. Nor do we take commission for referring anyone: whoever executes is a dedicated partner of the house, engaged and paid by us, within our price.
A conversation, with no materials and no proposal, to understand what is blocked. If there is matter to work on, the next step is the letter of authorisation and secrecy, a document that limits our own access before anything else. If there is not, we say so, and the conversation ends there.
Every statement on this page comes from a public norm, and the links above lead to the full text, not to the agency's portal. That is deliberate: whoever wants to check can check alone, without asking anything of anyone, which is the only kind of trust that does not depend on whoever asks for it.
No thesis moves forward without its classification written beside it. That is what separates a review from a promise.
Say in two lines what you need to resolve. An account manager replies personally, in business hours, and the conversation starts where it makes a difference.
This pagepoint the cameraIt reached the desk of whoever answers. The reply comes in writing, during business hours.
