Brazil: New Settlement Program for Disputes on Fines Imposed in Lieu of Forfeiture of Imported Goods

In brief

On September 18, 2026, Settlement Notice PGFN/RFB No. 5/2026 was published, setting out a joint proposal by the PGFN (Office of the General Counsel for the Federal Treasury) and the RFB (Brazilian Federal Revenue Service) for the settlement of tax disputes involving a relevant and widespread legal controversy.

The program covers debts under administrative or judicial dispute regarding the applicability and limits of the fines imposed in lieu of the forfeiture penalty, assessed in cases of fraudulent interposition of third parties or assignment of company’s identification to cover up foreign trade operations conducted by third parties.

Discounts range from 25% to 65% on the total debt amount, with a down payment and up to 61 installments.

Enrollment period: Until 7:00 p.m. (Brasília time) on December 29, 2026.

More details

The main features of the Notice are as follows:

We remain at your disposal to clarify any doubts you may have.