Asset pledge for tax appeals unconstitutional, Brazil's Supreme Court rules


Asset pledge for tax appeals unconstitutional, Brazil's Supreme Court rules


Brazil’s Supreme Court on March 28 took aim at a controversial practice that has sometimes made administrative tax appeals impractical for taxpayers: the requirement that the taxpayer make an asset pledge to secure a federal administrative tax appeal. The Court ruled that any asset pledge requirement for a taxpayer to secure an administrative appeal is a violation of the taxpayer’s constitutional right to a full and broad defense. (Unconstitutionality Direct Action No. 1976)