Through the publication of Ordinance MF No. 20, of February 17, 2023, the Brazilian Federal Revenue Service regulated the defenses of taxpayers in cases considered to be of low complexity, which are those whose value does not exceed 1,000 minimum wages.
From April 3, 2023, the date of the Ordinance’s effective date, the aforementioned low-complexity cases will be judged only in the first administrative instance and, in the last instance, by a collegiate decision in the Appeals Panels.
The measure aimed to reduce the number of cases to be judged by the Administrative Council of Tax Appeals (CARF) and to speed up the judgment of cases whose value involved is not considered high by the Federal Revenue Service.