Tax settlement of outstanding debts in the State of São Paulo – Ruling No. 27/2020


In brief, the State Attorney General Office in São Paulo, in line with the federal tax settlement program, published in the Official Gazette on the 24th of November 2020 Ruling No. 27/2020, after the State program was created in by Law No. 17,293/2020.

This is an alternative of settling directly with the State Attorney General Office in the situations addressed therein and a new trend for reducing litigation levels.

Please find below an overview of the main aspects of Ruling No. 27/2020:
·       Deadline for settling: There is no deadline
·       Who is it designed for: Individuals or companies (including inapt companies, bankrupted companies or companies under judicial reorganization)
·       Categories:
(i) Settlement by adhesion, mandatory for taxpayers owing R$ 10 million or less.
(ii) Individual settlement, for the taxpayers owing taxes over R$ 10 million, even if decides to settle part of the debts.
·       Benefits:
(i) Discounts on the fines and interests (depending of the debt recoverability level);
(ii) Payment in installment;
(iii) Deferral on the payment;
(iv) Moratorium;
(v) Substitution and selling of assets placed as guarantee
We estimate that a normative ruling will be soon enacted for regulate the settlement by adhesion. The individual settlement is full regulated by Ruling No. 27/2020
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