Artur Sahione Muxfeldt and Marcelo Silveira co-author an article in Valor Econômico on the Habitual Tax Debtor Law

Our specialists Artur Sahione Muxfeldt and Marcelo Silveira co-author an article published in Valor Econômico on the Habitual Tax Debtor Law and its implications for Brazilian states and municipalities.

The article analyzes the developments introduced by Supplementary Law No. 225/2026 in relation to the current state and municipal rules, establishing stricter criteria for the characterization of habitual tax delinquency, as well as a specific procedure ensuring the right to due process and a full defense.

The text highlights the challenges involved in implementing the new framework at the state and municipal levels, including the need to adapt local legislation within a period of up to one year. The authors also draw attention to the treatment that should be afforded to taxpayers who have already been classified as habitual tax debtors under previous legislation, particularly given the need to ensure the safeguards provided for under the new federal law.

The topic underscores the importance of closely monitoring legislative developments at the state and municipal levels to ensure compliance with the criteria and procedures established under the new legislation, while properly distinguishing between taxpayers who systematically use non-payment of taxes as a competitive strategy and those who, in the face of adverse economic circumstances, seek to regularize their tax situation.

Read the full article.