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:
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.