The Brazilian Federal Revenue Service has published a new ordinance authorizing the use of tax loss carryforwards and negative CSLL basis credits to offset debts included in tax settlement agreements. The measure follows a decision by the Federal Court of Accounts (TCU) and changes the dynamics of negotiations within administrative tax disputes.
According to Leonardo Pestana, attorney at CMC, the change represents a significant step forward in the use of tax assets by companies, especially in tax regularization scenarios and negotiations with the National Treasury.
The topic was covered by JOTA in a report addressing the practical impacts of the new regulation.
Read the full article: https://www.jota.info/tributos/receita-libera-uso-de-prejuizo-fiscal-para-amortizar-credito-em-transacoes