The new transaction, called the "SOS-RS Transaction", was instituted by PGFN/MF Ordinance No. 1032/2024 and grants up to a 100% discount on fines, interest and legal charges levied on debts registered as Federal Active Debt, in addition to the installment payment of the outstanding balance in up to 120 monthly installments. For individuals, micro-enterprises, small businesses, Holy Houses of Mercy, cooperatives and other civil society organizations and educational institutions, the installment plan can be up to 145 installments.
It should be noted that the installments are increasing, i.e. they increase over time. The percentage increase can be found at the following link: SOS-RS transactions
Debts registered as Active Debt until June 26, 2024, with a total value equal to or less than R$45 million, can be included in the new type of transaction. The difference between the SOS-RS Transaction and the others offered on the PGFN's Regularize portal is that, when calculating the taxpayer's ability to pay, it takes into account the gross revenue for the months of May to June 2024, the critical period of the floods, establishing a relationship with the same period in 2023.
By calculating the taxpayer's ability to pay, they learn their tax classification, which influences the percentage discount granted for payment. In this case, taxpayers in categories C and D are the only ones to benefit from the discount, which can be up to 70% of each CDA for individuals, MEs, EPPs, Santas Casas and cooperatives, or up to 65% for other legal entities.
It is important to note that, even though it was granted under exceptional conditions and aimed at offering help in this post-climate disaster period, the transaction is subject to the general rule that, if terminated, it prevents the taxpayer from entering into new transactions for a period of two years. Non-payment of three consecutive or three alternating installments is grounds for termination.
By: Laura de Oliveira Mello Figueiredo
In a recent decision, the Third Panel of the Superior Court of Justice (STJ) upheld the extrajudicial exclusion of a partner based on a private instrument signed by all members of the company, even without registration with the Board of Trade.[1]
In the case under review, after the company's formation and registration, the partners signed a document called a "statute," [...]
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On March 18, 2025, at the Hotel Laghetto Stilo Higienópolis, Thomas Dulac Müller, a lawyer and expert in corporate restructuring, participated in the panel "Third-Party Liability in Bankruptcy", sharing his expertise alongside top industry specialists. The discussion provided strategic insights into the legal implications of bankruptcy for third parties involved in insolvency proceedings. […]
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