The National Treasury Attorney General’s Office (PGFN) increased the limit for using tax losses and negative CSLL bases to settle debts from 10% to 30%, under the first three calls for proposals under the Comprehensive Settlement Program (PTI). The change applies to debts registered as active debt that are related to theses of significant legal controversy and may be applied until June 30, 2025.
With this change, taxpayers will be able to deduct up to 30% of the final amount of the debt with tax losses, in addition to other discounts offered depending on the chosen method. In specific cases, the total discount can reach up to 75% of the original debt.
From our perspective, the increase in the limit represents a relevant opportunity for companies that accumulate tax losses, but were previously unable to effectively leverage them in transactions with the National Treasury.
It is important to emphasize, however, that there are still restrictions — such as the requirement to fully convert judicial deposits into federal income for the application of benefits — that deserve careful analysis before joining.
We recommend that interested companies evaluate the scenario in depth, considering the economic and accounting impacts of joining the program.
