Brazil settles tax disputes with banks
Brazil’s Attorney General’s Office for the National Treasury (PGFN) has reached agreements with Itaú, Santander and Citibank to end court disputes and settle BRL2.5bn ($470mn) in outstanding tax claims, the agency said, as the government seeks additional revenue to meet fiscal targets.
The deals were signed under the Comprehensive Transaction Programme, which is designed to reduce litigation between companies and the federal government and form part of the finance ministry’s revenue strategy, Estadão reported.
Santander agreed terms covering BRL1.5bn, while Citibank settled around BRL500mn. Both cases involved liabilities linked to the former financial transactions tax, CPMF, which was scrapped in 2007.
Itaú negotiated about BRL1bn in claims related to PIS/Cofins on financial income, corporate income tax and the social contribution on net profit.
Separately, the Minas Gerais Development Bank settled more than BRL200mn tied to PIS and Cofins assessments.
Altogether, negotiations with large financial institutions involved BRL3.3bn in disputed amounts, reflecting total claims rather than sums paid. Discounts granted by PGFN ranged from 10% to 30%, with Itaú receiving a 10% reduction.
Between January and September 2025, PGFN recovered BRL44.9bn, with transactions accounting for more than half.
“In the agreements already reached, the discounts ranged from 10% to 30%, depending on the timeframe and specific situation of each legal proceeding, with payment of the remaining balance upfront, guaranteeing the Union recovers significant amounts that could take years to collect,” said Mariana Lellis Vieira, PGFN’s general coordinator of negotiations.

