A new feature introduced by Law No. 13,988/2020, the possibility of a transaction with the Federal Union to end disputes related to Public Treasury credits of a tax or non-tax nature has been consolidated as an effective instrument for taxpayers to resolve their pending issues with the Attorney General’s Office of the National Treasury.
Although the transaction is a means of extinguishing the tax credit (CTN, art. 156, III), the fact is that the Judiciary has equated it to an installment plan, regarding the extension of its effects for criminal tax purposes.
Thus, Crimes Against the Tax Order will be suspended until all payments stipulated in the transaction are made, which includes a possible police investigation to investigate them. This was the position of the Federal Regional Court of the 3rd Region, which can be considered a small safeguard for taxpayers against the tax authorities’ arsenal of tools to enforce tax collection.
