By Gabriela Marugal Munhoz Rodrigues and Mariana Brambilla

In 2025, the Brazilian Federal Revenue Service (Receita Federal) implemented significant changes to the PER/DCOMP Web system, particularly regarding the qualification and use of tax credits arising from final and unappealable judicial decisions. These changes directly impact the routine of taxpayers — both individuals and legal entities — who have prevailed in tax lawsuits and intend to use the resulting credits for tax offsetting.

Previously, individuals filed the DCOMP using a form. However, as of February 15, 2025, individuals are required to submit the DCOMP electronically via the PER/DCOMP Web system, thereby unifying the procedure with that of legal entities.

Additionally, certain situations qualify as “Credit in Special Circumstances,” a field exclusive to individuals, which include:

• PER/DCOMP filed by the administrator or heir of an estate, in cases where the taxpayer entitled to the credit is deceased.
• PER/DCOMP filed by the legal guardian of a minor or legally incapacitated taxpayer.
• PER/DCOMP filed by an attorney, in cases where the taxpayer has permanently left Brazil.

One of the main innovations is the mandatory itemization of the installments that make up the judicial credit at the time of completing the DCOMP.

Under the previous layout, it was sufficient to indicate the total amount of the judicially recognized and updated credit as of the date of the first DCOMP filing. There was no requirement to individually report the payments that originated the credit.

Under the new layout, each installment must be itemized and described with detailed information, such as: date of collection, tax period, revenue code, principal amount, penalties, interest, and the start date of monetary adjustment. The main fields available for credit breakdown include:

• Payment – GPS: Displayed when the judicial claim originates from a social security matter. This field should be used when the taxpayer includes amounts paid via GPS to compose the judicial credit.
• Payment – Other Collection Documents: This field is used when the credit includes payments made via DARF. To locate the payment, the taxpayer can use the “search” field to find the desired DARF by document number and select the corresponding revenue code. The taxpayer must also report the amount of the undue/excess payment related to the selected DARF.
• Payments – Other: This field must be used to include values that cannot be reported in the other tabs, such as: Negative Balances of IRPJ and CSLL, Reintegra credits, and Non-Cumulative IPI credits, among others.

There is also the option to forgo itemized breakdowns in exceptional cases where it is not feasible to reconcile the credit usage control. In such cases, the taxpayer may opt to omit the breakdown, but must complete the “Original Credit as of Filing Date” and “Updated Credit as of Filing Date” fields and assume full responsibility for maintaining internal control over credit usage.

Judicial credit qualification remains a mandatory requirement for submitting the DCOMP, along with the applicable deadlines: within five years from the final and unappealable decision if execution has not begun, or within five years from the court’s approval of execution withdrawal, if execution was initiated.

Previously, taxpayers manually entered the amount in the “Updated Credit as of Filing Date” field, which required internal control and calculations. With the new layout, specific fields — such as the Selic-based credit update — will now be calculated automatically by the system.

The new manual also includes a dictionary of potential error messages that may appear if any information is inconsistent. In such cases, the PER/DCOMP cannot be submitted until the errors are corrected.

These changes aim to enhance legal certainty and control over the use of judicially recognized credits. On the other hand, they demand meticulous efforts from taxpayers and their representatives, especially in the comprehensive mapping of the payments and withholdings that gave rise to the credits.

In this context, heightened attention to the qualification stage and the structuring of credit breakdowns is essential to avoid future disallowances and to safeguard the company’s tax planning.

The Tax Advisory Team at Marins Bertoldi Advogados remains available to clarify any questions or concerns regarding the new procedures and regulatory changes.