Correios sues to obtain clearance certificate despite R$1.3 billion in debt

The Brazilian Postal Service filed a lawsuit in Federal Court on July 2nd to secure the issuance of a tax clearance certificate from the Federal Revenue Service. The document was blocked by the tax authorities due to outstanding tax payments.
According to the state-owned company, the certificate is essential for the provision of public services and for maintaining contracts with the Public Administration. The document currently used by the Post Office would expire on July 6th.
The day after the lawsuit was filed, the Federal Court granted an injunction in favor of the Post Office. The Federal Revenue Service, however, did not immediately comply with the ruling, and the certificate was only issued on July 9th—see below.
Company claimed losses from “blouse tax” to request certificateIn its lawsuit against the tax authorities, the Postal Service claims to be facing financial difficulties, aggravated by external factors, such as regulatory changes in the import sector — the state-owned company's revenues were impacted, among other reasons, by the so-called "blouse tax."
"External factors such as regulatory changes in imports contributed to the contraction of the international segment. This resulted in lower mail volumes, increased competition, and, consequently, reduced revenue. This dynamic affected the company's expense structure, investments, and cash flow," the state-owned company's defense explained.
The Brazilian Postal Service's accumulated debt, referring solely to unpaid taxes between January and May 2025, amounts to R$1.36 billion—of which R$222 million corresponds to fines and interest. Estimates indicate that, in 2024 alone, the state-owned company's losses from taxes on international purchases reached R$2.2 billion.
The company's defense also argued that, as it is a federal public company, equivalent to the Public Treasury and responsible for an essential public service, the negative certificate should always be available — even in the face of tax issues.
"The legislation governing the company guarantees the non-attachability of its assets, income, and services, in addition to providing for tax exemptions, privileged jurisdiction, and differentiated procedural deadlines," the state-owned company stated.
Revenue issued positive certificate with negative effectsFollowing the court ruling, the Federal Revenue Service issued the certificate last Wednesday (9), after being repeatedly charged by the Federal Court. The Tax Authority issued a positive certificate with negative effects (CPEND) — a document issued when there are debts under judicial discussion or with suspended enforceability.
Since the amounts owed by Correios have not been paid, the negative certificate (CND) has not, in fact, been released. According to the IRS, the state-owned company still owes approximately R$1 billion in employer social security contributions (INSS), R$249 million in COFINS (National Institute of Social Security), and R$54 million in PIS (Public Interest Income Tax).
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