On 02/18/2015, the Brazilian Official Gazette published the Federal Revenue Office/Attorney-General Joint Administrative Ruling No. 02/2015, which regulates the federal tax installment program and the payment of tax debts with the Federal Revenue.

Joint Administrative Ruling No. 02/2015 provides taxpayers with a period of 30 days to pay their debts, or to file an administrative defense in the event of denial by the Federal Revenue Office of the payment of the relevant debts by way of set-off against tax losses accrued by the taxpayer, excepting cases where the tax loss accrued is subject of a tax assessment.

The aforementioned administrative defense will suspend the collection of tax debts that would be extinguished with the set-off, and those debts will not constitute an obstacle for the issue of clearance certificates. However, as the suspension of those amounts only lasts for 30 days counting from the official notification of the final decision, the taxpayer will only be able to pay the tax debt under the conditions of the tax installment program during this period.

Finally, in the event of lack of payment after the 30-day term, the Federal Revenue shall apply the rules relating to each early settlement plan.