The Ministry of Economy issued Ordinance No. 103/20 authorizing the Attorney General of the National Treasury to adopt a set of measures to suspend collection activities and facilitate renegotiation of overdue tax debts due to the coronarvirus pandemic (covid-19). The measures authorized on the basis of Executive Order No. 899/19 are the following:

I - suspend, for up to 90 days:

(a) the time limits for defending against administrative proceedings for collection of overdue tax debt of the Federal Government;

  1. b) the forwarding of certificates of overdue tax debt for extrajudicial protest;

(c) the establishment of new procedures for the collection and liability of taxpayers; and

(d) the procedures for cancellation of payments for default.

II - offer a proposal for a transaction by adhesion related to debts registered as overdue tax of the Federal Government, upon payment of at least 1% of the total amount of the debt, with deferment of payment of the other installments for 90 days, subject to the maximum term of 84 months or up to 100 months for individuals, micro-companies, or small businesses, as well as the other conditions and limits established in Executive Order No. 899/19.

These measures for the adaptation of actions to collect the overdue tax debt of the Federal Government should be regulated by the PGFN in the coming days.

However, there is still no provision for extending the term of validity of clearance certificates, which is the taxpayers' claim in view of the current scenario.