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On April 7, 2025, Brazil’s Office of the Attorney General of the National Treasury (PGFN) issued Ordinance No. 721/2025, establishing new rules for tax settlements involving high‑economic‑impact federal tax credits under judicial dispute, based on the “Reasonable Potential of Judicial Credit” (PRJ) assessment.

What’s Changing?

The new framework introduces criteria that differ significantly from previous models. Now, discounts are determined by the length of the lawsuit and the PGFN’s assessment of the likelihood of success of the legal thesis being litigated — rather than the taxpayer’s Payment Capacity (CAPAG).

In other words, the policy no longer focuses on the debtor’s economic profile, but instead on the probability that the government will prevail in court regarding the disputed credit.

Who Can Apply?

To qualify for this settlement model, tax debts must meet all of the following requirements:

• Have a value equal to or greater than R$ 50 million per entry in the federal overdue tax register, with the possibility of including smaller amounts if linked to the same legal proceeding
• Be registered in the Union’s overdue tax register by April 7, 2025
• Be the subject of a lawsuit filed by the taxpayer challenging the tax enforcement
• Be fully guaranteed or have collection suspended by court order

What Conditions and Benefits Are Offered?

The new settlement program provides several advantages, including:

• Discounts of up to 65%, except on the principal amount
• Installment plans of up to 120 monthly payments
• Greater flexibility with guarantees, including substitution or release
• The option to use federal precatórios (court‑ordered government payment obligations) to amortize the debt
• Conversion of judicial deposits into final payment, with benefits applied to any remaining balance

What Is the Deadline to Apply?

Applications must be submitted by July 31, 2025, at 7:00 p.m. (Brasília time) and can only be completed through the Portal Regularize.

Official details are available on the Ministry of Finance’s website. If you’d like to understand how this new settlement model may affect your company or discuss tax regularization strategies, click here to contact the team at Donato & Garcia Neto Advogados.