Artur Sahione Muxfeldt comments on new Brazilian Federal Revenue Service regulation for Valor Econômico

Our partner Artur Sahione Muxfeldt was interviewed by Valor Econômico for an article regarding a new Federal Revenue Service rule that alters the administrative dispute process for taxpayers classified as “habitual debtors” (devedores contumazes).

The report covers RFB Ordinance No. 702, which establishes that appeals filed by such taxpayers will now be adjudicated—at the second and final administrative level—by the appellate panels of the Federal Revenue’s Appellate Adjudication Office, bypassing the Administrative Council of Tax Appeals (CARF).

In his analysis, Artur highlights that this new procedure represents yet another sanction imposed on taxpayers classified as habitual debtors and notes that it may raise questions regarding the principle of equal treatment within the federal administrative dispute system.

This issue underscores the gravity of being classified as a habitual debtor, given the significant legal consequences that stem from such a designation.

Click here to read the full article.