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RFB regulates and restricts fine exclusions in cases judged by CARF through a tie-breaking vote
August 15th, 2024
On July 24, 2024, the Brazilian Federal Revenue Service (“RFB”) published Normative Ruling (“IN”) No. 2,205/2024, regulating the effects of Articles 25, §9-A and 25-A of Decree No. 70,235/1972 – introduced by Law No. 14,689/2023 – to address the exclusion offines, the cancellation of tax representation for criminal purposes and the regularization of tax debts in cases judged by the Administrative Tax Appeals Tribunal (“CARF”) in favor of the Brazilian National Treasury by a tie-breaking vote.
The IN RFB No. 2,205/2024 restricted the possibility of suspending isolated fines, customs fines, and default fines in case of a tie-breaking vote in favor of the tax authorities.
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Demarest’s Tax team is available to provide any additional clarifications that may be necessary on these matters, seeking to define the best strategy for each case.
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