On 27 March 2024, Decree No. 281/2024 (“Decree”) was published in the Official Gazette. The Decree extends the deadline for repatriating financial assets of at least 5% of the total value of assets located abroad from 31 March 2024 to 30 April 2024, inclusive.
As a reminder, the applicable personal assets tax rates for assets located abroad will be the same as those applicable to assets located in Argentina if, before 31 March of each year, taxpayers repatriate financial assets of at least 5% of the total value of assets located abroad and if certain additional requirements have been met.

On 19 March 2024, the Public Notice of Special Settlement Agreement No. 1/2024 was published, which provides for the opening of the Zero Litigation Program 2024, a new special settlement agreement for tax debts in administrative litigation within the scope of the IRS of Brazil, the value of which, per litigation, is up to BRL 50,000,000.00. Discounts and payment terms will be determined according to the degree of recoverability of the debts. The deadline for joining the Program is 1 April 2024 to 31 July 2024.

On 3 April 2024, the Federal Revenue of Brazil (RFB) issued Normative Instruction No. 2184/2024, which regulates the tax transaction provided in Article 14 of Law 14789/2023. This transaction aims to encourage companies to pay IRPJ and CSLL (corporate income taxes), resulting from the exclusion of investment subsidies made in disagreement with Article 30 of Law No. 12973 of 13 May 2014, provided that they have not been subject to assessment.

On 28 February 2024, the NBR notified taxpayers via email and an announcement on its webpage that the record retention requirement for Value-Added Tax has been extended from five to ten years. The initial five-year record retention period for the 1 January 2018 – 31 March 2018 tax period (Q1 2018) would have lapsed as of 31 March 2024, but now has been extended to 31 March 2029.