PGDAU Notice No. 11/2025: Tax Settlement for Debt Regularization

The Brazilian Attorney General's Office of the National Treasury (PGFN) has published PGDAU Notice No. 11/2025 (the “Notice”), which sets forth the conditions for tax settlements to regularize debts up to BRL 45 million enrolled into overdue federal liabilities.

Taxpayers must register their intention to settle with the Regularize website by September 30, 2025.

The Notice establishes four types of settlement and covers debts enrolled into overdue federal liabilities (whether tax-related or not) up to March 4, 2025 — except for the "Small-Value Settlement" modality, which covers debts registered up until June 2, 2025.

The taxpayer must include all eligible debts, except for those that have guarantee or that are already included in installment plans, previously settled through a transaction, or with enforceability suspended by judicial decision. However, combining different settlement modalities is allowed, including:

• Settlement Based on Payment Capacity;
• Settlement of Debts Deemed Irrecoverable;
• Settlement of Small-Value Debts; and
• Settlement of Debts with Guarantee Insurance or Letter of Bank Guarantee.

The use of tax losses or negative tax basis of CSLL (Social Contribution on Net Profit) to settle debts is prohibited, and the taxpayers who have had a settlement terminated (with cause) in the past two years are not eligible.

An important point to note is that the registry of the debts into this program will result in the automatic conversion of existing judicial deposits as a definitive payment, so that the conditions for the settlement will only apply to the remaining balance.

Among the benefits, we emphasize the following:

• The option to pay the debt in up to 108 or 133 monthly installments, depending on the terms of the settlement;
• Discounts of up to 100% in interest, fines, and legal charges, subject to limits of 65% to 70%, depending on the taxpayer and the chosen modality; and
• Down payments ranging from 5% to 6% of the total consolidated debt, which can be paid in up to 6 or 12 installments, depending on the terms of the settlement.

For more information regarding this notice, please contact our tax team at: TaxpartnersTC@mayerbrown.com