On October 1, 2025, the Ministry of Finance published an ordinance introducing relevant changes to the procedures applicable to tax litigation before the Federal Revenue Service’s Regional Delegations.
The new regulation seeks to standardize and expedite the analysis of administrative tax proceedings, strengthening procedural guarantees for taxpayers and ensuring greater uniformity in decisions.
Among the main innovations are:
- Expanded jurisdiction of judgment panels, with clearer rules on competence and voting procedures.
- Increased transparency, with mandatory disclosure of decisions and enhanced access for taxpayers to the full content of rulings.
- Procedural streamlining, reducing unnecessary formalities and aiming at faster resolution of disputes.
- Integration with digital systems, reinforcing the use of electronic platforms for filing, monitoring, and judgment of cases.
The measure is aligned with broader efforts to modernize Brazil’s tax litigation framework, reduce administrative backlog, and promote legal certainty in the relationship between taxpayers and the Federal Revenue Service.
For companies and individuals involved in tax disputes, the reform represents both an opportunity and a challenge: while it may accelerate the resolution of controversies, it will also demand closer monitoring of procedural deadlines and compliance with the new requirements.