On 31 July 2025, the São Paulo State Department of Finance and Planning published SER Ordinance No. 43 and SFP Resolution No. 22, authorising the 12th round of the Liquidity Enhancement Programme for Credits of Taxpayers with a History of Acquiring Goods for Fixed Assets (“ProAtivo”), created in 2021.
The programme aims to gradually enable the transfer of accumulated ICMS credits by taxpayers who face difficulties in using these amounts in their operations. Under the new Resolution, a total of BRL 1.5 billion will be released — the highest amount authorised since the programme’s inception.
Despite this significant amount, BRL 1.5 billion represents only about 15% of the stock of accumulated credits already recognised by the Tax Administration, which exceeds BRL 9.1 billion. This release therefore still falls short of meeting the real needs of companies that have been waiting, in some cases for years, for the reimbursement of overpaid taxes.
The 12th round introduces a priority criterion: higher amounts will be allocated to São Paulo companies that, between 2021 and 2024, exported more than BRL 20 million to the United States — a group directly affected by tariff measures adopted by the US government. For these companies, the individual release limit will be BRL 120 million. For other taxpayers, the maximum limit remains BRL 30 million.
Applications can be submitted from 12 August 2025, exclusively through Sefaz-SP’s Electronic Petition System (SIPET). The approved amounts will be paid in 10 monthly instalments starting in September, subject to a global limit of BRL 150 million per month. This means that the amount actually received by each taxpayer will depend directly on the total number of participants. In the previous round, for example, the average paid to companies requesting the maximum amount was around BRL 12 million, due to high demand.
Given the complexity of the process, the instability in releases, and the requirement for specific documentation, it is crucial for companies to be well-advised to ensure safe and efficient participation in the programme, as well as to explore complementary alternatives for recovering accumulated credits.
