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The parties (Attorney's Office and taxpayer, through their lawyers) which, within the limits of legal and infra-legal provisions, will lead to the conclusion of a specific transaction for that taxpayer and which considers individual data on your economic and tax situation. In this article we will discuss the individual transaction proposed by the taxpayer , in cases of debts exceeding 10 million reais . According to the law, the points on which the transaction may take place are: 1) Discount on the value of the debt, which, according to the law, cannot be on the value of the tax itself — it can only apply to fines and interest; cannot reduce a criminal fine, nor can it reduce the debt, as a rule [6] , by more than 65% of its value.

Number of installments, considering a maximum of 120 [7] installments. 3) Guarantees: for a transaction to take place, as a rule, there must be a guarantee, but it does not necessarily need to be in cash or real estate, because the Belgium Phone Number Data taxpayer will often not be able to present this type of guarantee; and may not cover the entire debt. 4) Possibility of using the balance of tax losses or negative basis to pay part of the debt, or federal tax credits that the taxpayer has, or third parties, if there is a correct assignment. 5) Possibility of payment by court orders, as long as legal rules are followed.



Therefore, considering that these are the main points to be negotiated, it is important to understand how the intention of carrying out the individual transaction arises for the taxpayer. We need to note that, in practice, for an individual transaction to begin, a process must be in progress and there must be litigation [8] . Typically, the taxpayer eligible for the individual transaction has several disputes in which there is little chance of effective payment of the required tax credits. The National Treasury Attorney's Office, in turn, is choosing taxpayers and processes to act more incisively with the aim of recovering the tax credit.
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