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ARTICLE · 03 APRIL 2024

Tax Settlement Adhesion Notice No. 01/2024: Zero Litigation Program 2024

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On March 19, 2024, Adhesion Transaction Notice No. 01/2024 ("Zero Litigation Program 2024" or the "Program") was published, paving the way for tax settlements between taxpayers and the Brazilian Federal Revenue.

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On March 19, 2024, Adhesion Transaction Notice No. 01/2024 ("Zero Litigation Program 2024" or the "Program") was published, paving the way for tax settlements between taxpayers and the Brazilian Federal Revenue. Through the Program, taxpayers can have the reduction of interests, fines and legal charges for tax credits being challenged in the Administrative Court, while the proceedings are underway at the Brazilian Federal Revenue Judgement Offices ("DRJ") or the Administrative Council for Tax Appeals ("CARF"), when the value of the credits do not exceed R$50 million.

Some key benefits of the Program are potential discounts for credits considered difficult or impossible to recover, special installment payment conditions, and the option to use credits resulting from tax losses and negative CSLL calculation bases calculated up to December 31, 2023.

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Founded in 2001, Tauil & Chequer Advogados is a full service law firm with approximately 90 lawyers and offices in Rio de Janeiro, São Paulo and Vitória. T&C represents local and international businesses on their domestic and cross-border activities and offers clients the full range of legal services including: corporate and M&A; debt and equity capital markets; banking and finance; employment and benefits; environmental; intellectual property; litigation and dispute resolution; restructuring, bankruptcy and insolvency; tax; and real estate. The firm has a particularly strong and longstanding presence in the energy, oil and gas and infrastructure industries as well as with pension and investment funds. In December 2009, T&C entered into an agreement to operate in association with Mayer Brown LLP and become "Tauil & Chequer Advogados in association with Mayer Brown LLP."

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This article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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