Insights

Tax act's pathologies and invalidities

The nature and limits of Tax Administration actions, their defects (vices), and the legal remedies under the regime of invalidities.

Fiscal Constitution and fundamental rights

The application and defeasibility of tax laws in light of the Fiscal Constitution and the reinforced principle of fiscal legality (juridicidade fiscal).

Tax sustainability and system trust

The sustainability and legitimacy of the tax system, rebalancing the tax litigation pyramid, and the role of taxation in building robust institutions and achieving the SDGs.

Technology and the new tax administration paradigm

The transition of the Tax Administration from a collection authority to a regulatory entity, the progressive implementation of the compliance-by-design paradigm, the use of Artificial Intelligence in tax management, and the emerging challenges to taxpayers' rights.