The First Panel of the Superior Court of Justice (STJ) has admitted Topic 1,350 to determine whether the Public Treasury may replace or amend the Tax Debt Certificate (CDA) by including or altering the legal grounds for the charge up until the judgment in tax enforcement proceedings.
Our Tax team has prepared a comprehensive analysis of the potential impact of this discussion for taxpayers, as well as its implications for the principles of due process and legal certainty.
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