Administrative Tax Litigation
Defence against tax assessments, from the first challenge to CARF and TIT.
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A tax assessment can be challenged before it becomes a registered tax debt.
While the administrative dispute is pending, collection of the debt is suspended.
What we do
- Challenges and objections at the federal level
- Appeals and oral argument before CARF (Federal Administrative Tax Court)
- Defence against ICMS assessments (AIIM) and appeals to the São Paulo Tax Court (TIT)
- Responding to tax audit summonses and notices
Frequently asked questions
What is the deadline to challenge a federal tax assessment?+
Thirty days from notice (Decree 70,235/1972, art. 15).
Is it worth disputing at the administrative level?+
In many cases, since there are no adverse costs and collection is suspended during the dispute. The decision depends on the amount, the argument and the tribunal's case law.
Practice
Areas of a single tax practice.