PGFN Notice No. 6/2026 has reopened the available tax settlement (transação tributária) programs for the negotiation of federal tax debts registered as overdue federal liabilities, reinforcing tax settlements as an important alternative to traditional installment payment plans.

The initiative brings positive aspects, including the preservation of terms and conditions already familiar to taxpayers. However, it also leaves an important gap: the notice does not allow the use of tax loss carryforwards and negative tax bases as payment credits, a mechanism already recognized by Brazil’s Federal Court of Accounts (TCU) and provided for by the Brazilian Federal Revenue Service under RFB Ordinance No. 676/2026 for tax liabilities under administrative dispute.

It is a missed opportunity that, hopefully, will be addressed in future notices.

In an article published by LexLegal, our attorney Leonardo Pestana examines the scope of the notice and its practical implications for taxpayers with significant tax liabilities.

Read the full article: https://lexlegal.com.br/pgfn-insiste-em-modelo-de-negociacao-e-perde-chance-de-ampliar-negociacao/