By Vinícius Encinas Paz and Mariana Brambilla Bertasso 

The State of Paraná has established a Tax Recovery Program (REFIS), called Regulariza Paraná, through Law No. 22,764/2025, published on November 4, 2025, for the settlement of tax and non-tax debts. The authorization for this new program followed the signing of ICMS Agreement No. 72/2025 by CONFAZ on July 4, 2025.

Under the new rules, ICMS credits—whether constituted or not, including those voluntarily reported by taxpayers, under administrative or judicial dispute, enrolled or not in Active Debt, even if already subject to legal action and/or previous installment agreements—may be regularized, provided they arise from taxable events that occurred up to February 28, 2025. Reductions are granted for penalties and related legal additions, including those related to accessory obligations.

There are three ICMS installment payment options:

• Single payment, with a 95% reduction in late payment or tax penalty and 60% reduction in interest;
• Payment in 2 to 12 equal, monthly, and consecutive installments, with an 80% reduction in the penalty and 50% reduction in interest;
• Payment in 13 to 24 equal, monthly, and consecutive installments, with a 70% reduction in the penalty and 40% reduction in interest.

Taxpayers are not allowed to refund or offset amounts already paid, nor to use precatórios (court-ordered debts) or accumulated credits, even if previously approved by the tax authority.

Tax credits will be consolidated on the date of the installment request, including all legal additions provided under current legislation. Interest corresponding to the SELIC rate will apply, compounded monthly from the month following approval, plus 1% in the month of payment.

For installment agreements involving debts already under legal action, adherence will depend on proof of payment of legal fees or the first installment of the legal fees agreement. No new guarantees are required, and existing ones remain valid.

The deadline for joining the ICMS debt installment plan will be established by an Executive Branch regulation to be published within 30 days from the law’s publication date.

The program also provides for the settlement of tax credits related to the Motor Vehicle Property Tax (IPVA) for taxable events occurring up to December 31, 2024, through a single payment with a 95% reduction in fines and 60% reduction in interest.

Non-tax debts that can be settled under Regulariza Paraná include those related to other bodies and entities of the Direct or Indirect Public Administration, including those issued by the Instituto Água e Terra (IAT) and registered as Active Debt by the State Treasury Department (SEFA) up to November 4, 2025.

The payment and/or installment conditions for such debts are:

• Single payment, with a 60% reduction in late fees on the principal;
• Payment in up to 24 equal monthly installments, with a 50% reduction in late fees;
• Payment in up to 60 equal monthly installments, with a 40% reduction in late fees.

It is important to note that the installment agreement does not exempt the debtor from fulfilling any pending environmental repair obligations, including those formalized through a Damage Repair Commitment Agreement. Furthermore, participation in the Program is prohibited in cases where:

• The environmental violation resulted in human death;
• The offender is listed in the official register of employers who subjected workers to slavery-like conditions;
• Evidence of child labor exploitation was found during inspection;
• The violation involved abuse, mistreatment, or the use of cruel methods in handling animals.

Taxpayers may also rescind ongoing installment agreements to join the new program, forfeiting any previously granted benefits related to outstanding amounts.

From the second installment onward, the SELIC rate will apply to the amounts included in the agreement, compounded up to the due month on the principal and fine amounts. In cases of early payment, SELIC will apply similarly until the payment month. The minimum installment amount is set at 5 UPF/PR (Paraná Fiscal Standard Units), equivalent in November 2025 to R$ 733.90.

The Tax Law Department of Marins Bertoldi Advogados is available to clarify any questions regarding Regulariza Paraná.