This means that without a real, concrete and transparent

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Position regarding the total or partial classification of the legal entity in relation to the revenue arising from the CNAEs contained in the Ordinance, the taxpayer is completely at the mercy of the Tax Authorities , and may even be subject to fines.  with fines and interest. As an example, Regularize is a suitable channel for companies to adhere to the transaction provided for in the same law , as long as the taxes are due . Regarding the benefit at rate 0, which is forward, however, there is nothing like that.

Therefore, it is imperative that the Judiciary recognize the illegality present in the RFB's failure to make clear the classification of companies in Perse , whether through a system, or throughmust recognize the fair fear of companies under a writ of mandamus regarding future tax assessments". Urged to speak out to "clarify EX Mobile Phone Numbers whether there is an administrative a channel, or even a certificate, or any other means that certifies to the taxpayer's adherence and inclusion in the benefit, even though it is supposedly "self-applicable". In this exact sense, the 5th Federal Court of the Judiciary Section of Pernambuco recently decided, in the files of Process.



by declaring that "the first illegality presented by the petitioner is the Regulatory Power's own failure to create a system that allows companies to apply the zero rate provided for by law, without the fear of suffering sanctions from the Administration ", and that, "if, in fact, there is no system that recognizes the petitioner's status as a beneficiary of Perse, the Judiciary  procedure available to companies that do not have overdue debts to be administratively accommodated by Perse, regardless of a court decision; that is, to clarify whether there is an administrative procedure that avoids future mismatches between the amounts collected by the companies and the amounts understood as owed by the tax authorities, without the intervention of the Judiciary" , the Federal Revenue Service did not comment, allowing the deadline to elapse.