Tax settlements in Brazilian administrative litigation.

Eligibility, payment conditions and legal consequences for liabilities under administrative dispute.

RFB Notices No. 9 and 10/2026 create an assessment window for companies with tax assessments or denied offset claims pending before the Federal Revenue Service or CARF.

Eligibility, payment conditions and legal consequences for liabilities under administrative dispute.

RFB Notices No. 9 and 10/2026 create an assessment window for companies with tax assessments or denied offset claims pending before the Federal Revenue Service or CARF.

Who should pay attention

Companies with material administrative proceedings
Taxpayers with denied offset claims
Groups seeking predictability and contingency reduction

Eligibility

The review begins with the nature of the debt, procedural stage, consolidated amount and available settlement category.

Tax assessments under dispute
Denied offset claims
Proceedings before RFB or CARF

Economic conditions

Terms vary according to the credit’s recoverability and may combine down payments, installments, discounts and tax-loss utilization within program limits.

Consequences of joining

The decision must consider not only financial savings but also withdrawal of appeals, debt acknowledgment, guarantees and potential economic-group consequences.

Informational demonstration only. A settlement requires an individual review of the liability, proceeding and current terms.

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