Revenue classifies 17 more companies as persistent debtors

At the end of June and the beginning of July, the IRS had included five large companies in the cigarette sector on the list.

The complete list can be consulted on the panel of persistent debtors, a page created by the Revenue in June.

According to the body, the public list only includes taxpayers who completed all stages of the administrative process and had their eligibility definitively confirmed.

The list is dynamic and will be updated as new procedures are completed.

What is a persistent debtor?

The classification was created to combat companies that use repeated and unjustified non-payment of taxes as a business strategy. According to the Federal Revenue, the measure seeks to strengthen tax compliance, encourage fair competition and provide more transparency to inspection actions.

The agency emphasizes that the initiative does not focus on companies facing temporary financial difficulties, but cases in which default is planned to generate a competitive advantage.

Right to full defense

Before joining the public list, the taxpayer goes through an administrative process that ensures the right to adversarial proceedings and full defense. During this procedure, the company can:

pay off debts in full;

pay the debt in installments;

present administrative defense;

prove sufficient assets to exclude the classification;

appeal the decision if the defense is denied.

Only after an unfavorable final decision or lack of regularization does the company become officially considered a persistent debtor.

Criteria

According to Complementary Law No. 225/2026, which created the category of persistent debtors, the framework considers, among other requirements:

tax debt exceeding R$15 million; liabilities exceeding the assets declared by the company; repeated default, for consecutive or alternating periods, within 12 months.

The process involves different areas of the Federal Revenue Service and also the Attorney General's Office of the National Treasury (PGFN), responsible for debts registered as active debt.

Sectors

Notifications are concentrated, so far, in the cigarette and fuel sectors. According to the Revenue, the fuel segment alone accumulates debts in excess of R$30.6 billion, considering information from the agency and the PGFN.

The expectation is that inspection will be expanded to other economic segments with a history of high tax defaults. There is still no schedule for new notifications.

Restrictions

Companies classified as persistent debtors are subject to various restrictions provided for in legislation, including:

impediment to receiving tax benefits; prohibition of participating in public tenders; impossibility of adhering to certain regularization programs; restrictions related to judicial recovery; declaration of inability to register in the taxpayer register; cancellation of certifications obtained in compliance programs.

Exceptions

The legislation also establishes situations in which the company cannot be classified as a persistent debtor. Among them are:

debts paid in installments and paid regularly; taxes with liability suspended by court decision; amounts still under administrative discussion; relevant legal controversies; companies affected by public calamities or proven crises.

Furthermore, interest, fines and legal charges are not included in the calculation of the principal amount of the debt used for classification.