This understanding finds support in the constitutional protection of due process, the right to a fair hearing, and the right to a full defense, which guarantee a fair trial for the taxpayer.

Therefore, simply initiating proceedings to declare a company's CNPJ (Brazilian taxpayer identification number) ineligible is not sufficient; the administrative process must be exhausted before applying such a severe penalty, as the taxpayer may ultimately be able to obtain approval to maintain its social function.

For this reason, in cases of abuse of such magnitude that it results in the immobilization of a company's economic activities, the assistance of a specialized law firm becomes indispensable.

For more information, contact our team!

Decision commented on by Bárbara Melro Seabra, Lawyer, graduated in Law in 2016 from the Catholic University of Santos / SP, Specialist in Customs / Tax Law.
Brazilian Bar Association number 430.011