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Federal Revenue Service Announces “Historic Turn”: Promises to Become Less Punitive and Act as a Partner to Good Taxpayers, Expand Self-Regulation to Billions, Crack Down on Chronic Debtors, and Strengthen Legal Security with Coordination and Tax Reform

Published on 12/12/2025 at 11:35
Updated on 12/12/2025 at 11:36
Receita Federal lança Confia e amplia conformidade cooperativa com foco em segurança jurídica e avanços da Reforma Tributária para contribuintes brasileiros.
Receita Federal lança Confia e amplia conformidade cooperativa com foco em segurança jurídica e avanços da Reforma Tributária para contribuintes brasileiros.
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At the Launch of the Confia Program, the Federal Revenue Service Stated That It Wants to Exchange Reaction and Punishment for Trust, Cooperation, and Predictability. The Plan Includes Synchronization to Classify Taxpayers, Gradually Reduce Burden for the More Compliant, Expand Self-Regulation, Support the Tax Reform, and Crack Down on Chronic Debtors with International Support from the IDB.

On December 9, 2025, during the launch of Confia, the Federal Revenue Service stated that it has begun an institutional turnaround to be less punitive and more guidance-oriented, betting on cooperation with businesses and predictability to reduce litigation and increase legal certainty.

The official communication, following an event that brought together authorities from the federal government, the productive sector, and international organizations, focused on integrity, cooperative compliance, and the business environment.

CONFIA AND THE “HISTORICAL TURNAROUND” ANNOUNCED BY THE FEDERAL REVENUE SERVICE

Confia is presented as a Tax and Cooperative Compliance Program aimed at large taxpayers, based on trust, cooperation, and predictability.

According to the Federal Revenue Service, the proposal is to change the traditional logic of litigation and build a more transparent and continuous relationship with businesses, focusing on preventing disputes and enhancing legal certainty.

ROBINSON BARREIRINHAS: LESS PUNITIVE WITH THOSE WHO COMPLY, TOUGHER ON THOSE WHO DEFRAUD

The Special Secretary of the Federal Revenue Service, Robinson Barreirinhas, stated that the cultural change has been underway since 2023 and summarized the objective as “making the Federal Revenue Service less punitive, less reactive, and more guiding for good taxpayers”, while intensifying the fight against chronic debtors.

He also highlighted results from the self-regulation strategy: “we moved from a self-regulation level of billions to tens of billions of reais”, pointing out that guiding those who want to comply with regulations strengthens businesses and the treasury.

Barreirinhas also mentioned PLP 125, which has already been approved in the Senate and is awaiting analysis in the Chamber, as a cornerstone of the new logic, arguing that the project corrects a distortion in which tax law would be “harsh” on good taxpayers and “lenient” with chronic debtors.

FEDERAL REVENUE SERVICE AS A “PARTNER,” ALMOST A CONSULTANT, AND THE PROMISE OF TOTAL TRUST

In detailing Confia, Barreirinhas stated that the program inaugurates a relationship based on total trust, cooperation, and predictability.

The Federal Revenue Service describes the change as the transition from a solely reactive approach to a partnership stance with businesses, fostering dialogue and transparency to anticipate risks and reduce disputes.

SYNCHRONIZATION: CLASSIFICATION OF TAXPAYERS AND PROGRESSIVE BENEFITS

In the same package, the Federal Revenue Service highlighted Synchronization, described as a broad program to classify taxpayers according to their level of compliance.

The promise is to offer benefits similar to those of Confia, including progressive reduction of the tax burden for companies with better performance and greater adherence to obligations, reinforcing the incentive for cooperative behavior.

HADDAD LINKS CONFIA TO THE TAX REFORM AND THE ECONOMIC AGENDA

The Minister of Finance, Fernando Haddad, stated that the Federal Revenue Service plays a strategic role in the government’s economic agenda and linked Confia to ongoing structural transformations, especially the Tax Reform, which he said was built with extensive dialogue with society.

Haddad stated that the largest tax reform in the history of the country was forged with intense participation from the Federal Revenue Service, the productive sector, and federal entities.

He also mentioned advances in income taxation, measures against chronic debtors, and integrated operations with public security agencies, defending a relationship of respect in which “people should not fear the Revenue for punitive reasons”.

CNI, IDB, AND THE MOST CONTROVERSIAL MESSAGE OF THE EVENT: FROM “THE LION” TO “THE GUIDE DOG”

The Deputy Director of Industrial Development, Technology, and Innovation of CNI, Mário Sérgio Carraro, emphasized the symbolism of the event taking place at the headquarters of the entity and summarized the approach with a strong image: the Federal Revenue Service could stop being “the lion” and become “the guide dog,” guiding businesses on the right path.

For the Inter-American Development Bank (IDB), Maria Cristina Mac Dowell regarded the launch as a milestone for the country and for Latin America, stating that the Brazilian litigation is marked by high levels of disputes and legal uncertainties.

For her, programs such as Confia are fundamental to replacing a reactive and punitive logic with a cooperative and prospective logic.

Mac Dowell added that the IDB has supported the structuring of the technological and institutional base necessary for the new model, citing quality information, technical capacity, and internal cultural change as central requirements.

WHAT IS COOPERATIVE COMPLIANCE AND WHAT ARE THE “PIECES” OF THE MODEL

In the debates, the Federal Revenue Service and experts detailed Cooperative Compliance as an approach aimed at large taxpayers, structured around “justified trust,” continuous dialogue, and transparency between tax administration and companies, with the goal of preventing disputes and reinforcing predictability.
The tax auditor Andrea Costa Chaves listed the conceptual and institutional bases of the model, emphasizing: cultural and behavioral change, clear regulatory framework, suitable sanctions model, risk management, robustness in information collection and exchange, governance, and compatible administrative structure.

OECD: COLLABORATION DOES NOT ELIMINATE RIGOR, IT CHANGES THE WAY OF COLLECTING

The OECD representative, Manal Corwin, contextualized the origin of the concept of “enhanced relationship,” which evolved into the current focus on cooperative compliance.

She pointed out challenges in Brazil and Latin America related to trust and the complexity of tax laws and advocated advances in areas such as: replacing coercive measures with collaboration, strengthening governance and controls in companies, and accelerating the digital transformation of tax administrations with a focus on risk management, metrics, and prevention.

Corwin cited countries with similar models, such as Australia, the Netherlands, France, and the United States, and reinforced that cooperative compliance does not mean giving up rigor, but rather increasing predictability and effectiveness.

SPAIN: THE TURNAROUND BEGAN IN 2009 AND SWAPPED “TOM AND JERRY” FOR TRANSPARENCY

Representing the Institute of Fiscal Studies of Spain, Ignacio Corral stated that the key to any reform is the cultural change in the relationship between businesses and tax administration.

He compared the adversarial model to “Tom and Jerry,” as it is costly, conflictual, and inefficient. Corral explained that the Spanish experience began in 2009 with dialogue forums involving large corporations and evolved into an ecosystem of transparency, including a Code of Good Practices, annual transparency reports, fiscal control benchmarks integrated into governance, and regulatory evolution consolidating the model.

He also cited four levels of noncompliance adopted in the country and advocated for a sanctioning system that privileges cooperative behavior.

UNIVERSITY OF VIENNA: FOCUS ON SYSTEMS, NOT JUST TRANSACTIONS

From the University of Vienna, Jonathan Pemberton drew on the technical origin of the fiscal control framework developed from the OECD and explained that the goal is to ensure that large corporations meet obligations in complex environments.

The proposal, according to him, is to allow tax administration to focus on systems, rather than just individual transactions, as large companies deal with highly complex and multimillion operations.

Pemberton stated that the university is studying a unified model of minimal requirements for fiscal control benchmarks, with publication expected soon, to standardize inspections and support training in tax administrations.

CLOSING: THE FEDERAL REVENUE SERVICE BETS ON MODERNIZATION, BUT KEEPS THE MESSAGE ABOUT CHRONIC DEBTORS

In conclusion, the launch of Confia was presented as a reinforcement of the Federal Revenue Service’s commitment to a modern, transparent, and collaborative model, sponsored by the IDB and involving institutions such as the OECD, the Institute of Fiscal Studies of Spain, and the University of Vienna.

At the same time, the political message of the event was clear: partnership for those who comply, tightening for those who refuse to pay.

And you, do you believe that the Federal Revenue Service can truly turn the key and reduce taxpayer fear without easing the pressure on chronic debtors?

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Graça Silva
Graça Silva
16/12/2025 15:35

Quanto aos contumazes, duvido.

DANIEL GRATZ SPINASSE
DANIEL GRATZ SPINASSE
16/12/2025 11:10

Concordo com Giovani, quando a reforma tributária chegar mesmo a **** vai pro brejo , com um IVA de 28% e a desculpa que temos créditos como se o pequeno tivesse, não nos sustentaremos, fora os custos que vai exigir profissionais qualificados que não temos nem teremos, e nem dinheiro pra pagá-los, estou falando do pequeno e micro empresário que sustenta em empregos e impostos esse País, vamos aguardar pra ver ? Já ouvi muitos contadores e profissionais dizendo que vão desistir…. só Deus

Edwilson
Edwilson
16/12/2025 11:05

Se a Receita pode ser tão eficiente no controle dos impostos dos cidadãos que trabalham e contribuem, por que não o é no controle do uso dessa receita pelo Governo. Ou seja, a Receita sabe de todas as movimentações do cidadão, mas dos desvios feitos pelo governo não sabe nada.

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Maria Heloisa Barbosa Borges

Falo sobre construção, mineração, minas brasileiras, petróleo e grandes projetos ferroviários e de engenharia civil. Diariamente escrevo sobre curiosidades do mercado brasileiro.

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