The increased participation of taxpayers in administrative proceedings marks an important step forward in tax and customs litigation. With the Brazilian Federal Revenue Service's initiative to allow oral arguments even at the first instance, space is opened for a more complete, technical, and strategic defense from the beginning of the process, resulting in greater transparency, balance, and effectiveness.

In practice, this means that taxpayers will be able to present their arguments more clearly and directly to judges, contributing to better-founded decisions that are aligned with the reality of each case. It is a significant step towards strengthening the adversarial process and the right to a full defense in administrative proceedings.

Among the main benefits, the following stand out:

• Greater guarantee of the right to a fair hearing and full defense.
• Reducing errors in document analysis.
• More technical and assertive judgments
  Potential decrease in litigation in higher courts.
• This measure reinforces the importance of specialized legal representation from the very first instance, capable of transforming a sound legal argument into an effective outcome.

This measure reinforces the importance of specialized legal representation from the very first instance, capable of transforming a sound legal argument into an effective outcome.