through Article 33 of the provisional measure No. 651, of July 9, 2014, has been allowed to the taxpayer with parceling containing tax debts, due until 31 December 2013, the use of credits resulting from tax loss and of the CSLL negative calculation basis for early discharge purposes of parceled debts.

In turn, I override the joint concierge PGFN / RFB no. 15, August 25, 2014, which regulated such a modality of discharge of balances for parceled debts by: The Fiscal Recovery Program - REFIS (Law 9,964, of 10 April 2000), the PAES (Law 10,684, of 30 May 2003), the exceptional installment - PAEX (MP 303, 29 June 2006), the ordinary installment, the simplified installment and the 11.941 / 09 (CRISIS REFIS).

It deserves to be stressed, however, that it is necessary to pay value equivalent to at least 30% (thirty percent) of the debit balance of each modality of installment to be removed in kind. Such a requirement ended in many cases the use of tax losses and negative calculation base in the form treated here.

Finally, we clarify that the taxpayer should carry out accession until November 28, 2014, in the Unit of the Federal Revenue Revenue, presenting an early discharge request and the collection document, duly removed, concerning the anticipation of 30% of the debt value, among other documents.