Brazil's Federal Revenue Service Revises Rules for Repeat Tax Debtors

The Brazilian Federal Revenue Service (Receita Federal) issued Portaria RFB No. 702/2026, updating the procedures for its administrative litigation system. The amendment aligns the rules with Complementary Law No. 225 of 2026, which defines criteria for identifying repeat tax debtors.

Under the new regulation, voluntary appeals submitted by taxpayers classified as definite repeat delinquents will be judged, in a second and final administrative instance, by the review panels of the Delegacy for Tax Appeals (DRJ‑R), regardless of the dispute amount. Appeals will no longer be handled by the Administrative Council of Tax Appeals (CARF). The competent body for each appeal is determined by the taxpayer’s status at the time the appeal is filed, and any later change in classification will not retroactively affect jurisdiction.

The portaria also improves case‑management procedures: cases removed from a judgment agenda will be reinstated in the next published agenda, prior oral arguments will be disregarded, and parties may submit new written submissions within the regulated deadlines.