Losses may pay off part of the debt balance Another

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Innovation that made the transaction more interesting concerns the possibility of using tax losses, either own or from third parties (in particular, those companies linked to the main taxpayer), to pay up to 70% of the remaining balance of debts (after application of agreed discounts or reductions). In addition to tax losses, court orders or credit rights against the Union, recognized by a final and unappealable court decision, can be used to settle debts. This hypothesis allows the debtor to use less liquid assets and also reduce the impact of membership on their cash flow.

Another advantage is the possibility of offering any guarantees provided by law to ensure compliance with the transaction — including real or personal guarantees. The assignment of credit rights and the fiduciary alienation of assets or rights are permitted, as well as liquid and certain credits against the Union recognized EX Mobile Phone Numbers in a final and unappealable decision. Despite this, the eventual impossibility of offering guarantees by the taxpayer is not an impediment to carrying out a transaction. Finally, Law  provides that discounts granted in the Transaction will not be considered in the calculation basis of Corporate Income Tax, Social Contribution on Net Profit, nor contributions to PIS and Cofins.



Considering the Brazilian tax scenario and the evident need to reduce tax litigation, the innovations brought by Law reinforce the tax transaction as an alternative to be evaluated by taxpayers,  on the part of the creditor.MP extremely important step in the national financial system Elidie Palma Bifano August FinancialLawsTax The matter of the deductibility of the provision for doubtful debts (PCLD), for the purposes of calculating Income Tax and Social Contribution on Net Profit, within the scope of financial institutions, is old, dating back to the beginning of the 1990s and causing very large difficulties and costs in this segment of the economy.