The PGFN issued Ordinances 32 and 33, both of 2018, to regulate various procedures regarding the register of federal tax debts in the outstanding debts list (“Dívida Ativa”), such as notification of debtor, anticipated offer of assets as guarantee, the register of assets without court order, among others. Debts registered as outstanding in Dívida Ativa may be charged in courts through a tax foreclosure action.
It is worth mentioning that Ordinance 32 also stipulated a new administrative procedure, whereby taxpayers may request the review of registered debts by PGFN. Although this procedure allows for a limited scope of arguments, it brings a new opportunity of challenging tax debts before the tax debt is executed through a foreclosure action.
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