Brazil's Receita Federal Publishes First List of Persistent Tax Defaulters

The Federal Revenue Service (Receita Federal) released the first official list of taxpayers classified as “devedores contumazes” – persistent tax defaulters – after completing the administrative procedures established by Complementary Law 225/2026. The measure targets structured tax evasion and aims to curb unfair competition. To be classified, a company must owe more than R$ 15 million, have debt that exceeds its declared assets and show repeated non‑payment over a 12‑month period (four consecutive or six alternating defaults). The initial entries are from the tobacco (fumageiro) sector, whose debts exceed R$ 25 billion, and the fuels sector, with debts above R$ 30.6 billion. Affected entities were notified and given 30 days to settle the debt or submit a defence; those that failed to act were deemed “revel” and added to the list.

Being labelled a devedor contumaz triggers a series of sanctions: loss of tax benefits, exclusion from public tenders, ineligibility for special regularisation programmes, possible suspension of the CNPJ, restrictions on judicial recovery, declaration of inapt registration and cancellation of compliance seals. The Receita Federal created an online portal that publishes the list, explains the classification criteria, and provides guidance on renegotiation options and taxpayers’ right to defence. The policy does not target firms facing temporary financial difficulties; exemptions apply to debts under repayment plans, judicial suspensions, ongoing disputes, or companies affected by public calamities.