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ARTICLE · 05 SEPTEMBER 2024

Full Transaction Program Established To Reduce Federal Tax Litigation

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On August 30, 2024, Ordinance MF No. 1,383 was published, establishing the Full Transaction Program (PTI). The PTI provides a set of measures to reduce federal tax litigation with "high economic impact," encouraging...

BrazilTax
Carolina Bottino
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Carolina Ferraro
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On August 30, 2024, Ordinance MF No. 1,383 was published, establishing the Full Transaction Program (PTI). The PTI provides a set of measures to reduce federal tax litigation with "high economic impact," encouraging the Federal Government and taxpayers to settle.

Two Settlement Methods

The new program provides for two settlement methods:

  1. The first method applies only to credits under discussion at the judicial level, The credit will be based on the Reasonable Potential for Recovery of Judicialized Credit (PRJ). The PRJ is an index to be defined by the PGFN by assessing the prognosis and the degree of uncertainty of the result, as well as the average duration and recovery time of the credit.

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