Bill (PL) No. 508/23 was presented to the Chamber of Deputies, which provides for the limitation of the effects of the decision of the Supreme Federal Court (STF), through which the breach of res judicata was permitted.

The proposal records the maintenance of decisions favorable to taxpayers, which were issued up to 02/10/2023, two days after the Supreme Court’s decision on the breach of res judicata.

This bill goes against what was decided by the STF, given that the request for modulation of the effects of the decision, made by the taxpayer, was denied, with the request that the decision could only be valid after the date of its issuance.

According to the Project’s rapporteur, the text aims to ensure the taxpayer’s stability and reliability in the actions of the Public Authority.