In a recent decision, issued in the case of Special Appeal 1,656,172, the Superior Court of Justice understood that if there is evidence of fraud by a group of individuals and/or legal entities, such as the creation of fictitious legal entities to facilitate tax evasion or the depletion of assets of the real debtors, the execution court may... redirect tax enforcement to the people involved.
In these cases, the analysis will be carried out by the competent court based on its general power of caution and within the limits and conditions imposed by law – which allows the judge of the case “"Extend the order of asset freeze to guarantee all tax debts generated by the individuals involved in the illegal activity.".
Source: STJ
