The Perverted Administrative-tax Consensus

the PGFN and the Double Degree of Dialogue in Requests for Review of Registered Debt and Payment Capacity

Abstract

The text presents the efforts made by the Attorney General of the National Treasury (PGFN) to improve the efficiency of collecting the Federal Union’s active debt and reduce litigation. Next, after presenting the contours and limits of the principle of double degree of jurisdiction in accordance with the STF jurisprudence, it criticizes the PGFN’s insistence on guaranteeing the double degree to taxpayers, even in situations of simple openness to consensus such as the case of requests for review of registered debt and review of payment capacity. Finally, the author argues that, as it is not contentious in nature and there is no legal provision, the provision of administrative resources in both situations is a discretionary option by the PGFN that distorts the nature and objective of the dialogue, unnecessarily lengthening the resolution of the problem.