The recently enacted Law 13,606 authorizes the Office of the General Counsel to the Treasure (PGFN) to register assets from taxpayers with outstanding tax debts prior to a court order.

The register process is carried out by PGFN, which will verify the taxpayer’s assets available and immediately proceed with blocking those totaling the debt amount, favoring the assets in order of liquidity. The taxpayer may offer an asset to be registered pursuant to Ordinance PGFN 33/2018.

We understand that the register of assets without court order, as stipulated by law, is in breach of constitutional property and defense principles. Accordingly, there is notice of preliminary decisions recognizing that this measure is unconstitutional, and two Direct Unconstitutionality Actions filed against this measure.

For further information, please contact:

Henrique Lopes

Tatiana Vikanis

Victor Polizelli

Álvaro Lucasechi






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