On 1^st February 2017, the Diário Oficial da União (Official Federal Gazette) published Normative Ruling RFB No. 1.687 (“NI No. 1.687/2017”) regulating the Tax Regularisation Program (“TRP”), introduced by Provisional Measure No. 766/2017, under the auspices of the Secretaria da Receita Federal do Brasil (Brazilian Federal Revenue Secretariat, hereinafter referred to as the “RFB“).

The date of the publication of NI No. 1.687/2017 was that of the commencement of the period granted for registration with the TRP, which ends on 31 May 2017. The TRP registration protocol application shall be sent via Internet only, to www.rfb.gov.br.

Private individuals or companies registering for the TRP must include in their registration payments overdue up to 30 November 2016, regardless of whether or not they are tax-related or whether they are under administrative court or judicial court discussion. These also include officially recognised payables occurring subsequent to the date of this PM, and the possibility of including payables that were being paid under a rescinded or current instalment system.

It is possible to settle the outstanding balance through offset against credits arising from corporate income tax and CSLL (Social Contribution on Revenues) loses determined up to 31 December 2015 and declared up to 30 June 2016.

A taxpayer seeking to include in the TRP debts under administrative court or judicial court discussion should first withdraw from such cases.

We remain at your disposal for any further information you may require on this matter.

São Paulo, 3^rd February 2017.

Tax Department

Luis Augusto Gomes
lgomes@tesslaw.com

Davi Naves Grave
dgrave@tesslaw.com