PER/DCOMP in company liquidation: why doesn’t the procedure end with the cancellation of the National Register of Legal Entities?

When a company enters into liquidation, the focus typically falls on canceling the CNPJ, the winding down of operations and the fulfilling of immediate obligations. During this period, administrative procedures that are still ongoing, such as the Electronic Request for Refund, Reimbursement or Restitution and Compensation Statement (PERD/DCOM), are often no longer monitored.

The idea that “once a company is liquidated, the matter is closed” does not apply when there are actives PER/DCOMP, whether for reimbursement or compensation. Failing to address this issue could result in financial losses and outstanding tax obligations.

PER/DCOMP does not automatically close upon liquidation

PER/DCOMP remains active even after the cancellation of the CNPJ; therefore, its verification should be included in the company’s closing checklist. Without monitoring, the Federal Revenue Service Office may later request documents, demand supporting evidence, or complete analyses. In practice, this monitoring can extend for up to five years, a typical timeframe for tax audits—which reinforces the need for continuous monitoring even after formal liquidation.

The false sense of termination and its practical effects

In many liquidation processes, the existence of pending PER/DCOMP is not verified beforehand. The process is forgotten, based on the assumption that there will be no further demonstrations.

When the Revenue Service contacts the company months or years later, it becomes clear that the request was still being processed—and that there was a lack of monitoring. In other words, the problem is not with the PER/DCOMP system, but with the lack of follow-up.

Requesting a refund or compensation requires ongoing tax monitoring

Requests for refunds or compensation involve detailed analyses by the Revenue Service, which may include:

• Proof of origin of the credits;
• Presentation of documents from previous fiscal years;
• Analysis of operations; and
• Revisions to previously declared information.

Therefore, leaving the PER/DCOMP without monitoring after liquidation exposes the company to requirements that demand technical answers and organized documentation, and the last legal representative (an individual) remains responsible for responding to summons, providing clarifications, and supplying documents until the final conclusion of the process

Responsible liquidation requires attention to what remains under analysis

The liquidation does not automatically terminate administrative obligations. Procedures such as PER/DCOMP continue to have effects and should be monitored until completion.

Ignoring this aspect can result in financial losses or unmet tax requirements. Therefore, monitoring PER/DCOMP should be part of a responsible and thorough liquidation process.

PLBrasil Accounting&Finance provides technical support for PER/DCOMP during liquidation processes, ensuring that credits and liabilities are handled correctly and that no outstanding issues remain after the liquidation is concluded.