Instrument to be used by the Union. This is because the tax transaction has always had the ability to bring not only greater speed to the resolution of conflicts and, consequently, a reduction in litigation, but also the greater effectiveness, especially in terms of the active participation of taxpayers in the procedure for applying the rules, which allows for a closer relationship between the parties involved. With the advent of Law No. 14,375/2022 and the changes resulting from it, there was an even greater facilitation for carrying out these transactions.
Regarding the participation of those involved, the main one concerns the direct action of the Federal Revenue Service in negotiations of existing debts with those administered. Before Law No. 14,375/2022, it was only allowed to transact debts EX Mobile Phone Numbers under the administration of the Special Secretariat of Revenue as long as there was no judicialization, including on the part of the taxpayer. there is an express change to make judicialization irrelevant, as long as the debt is under the administration of the Revenue for the transaction to be carried out without the need for the Attorney General of the National Treasury (PGFN) to act. In other words, it is enough not to have been enrolled in active debt yet.
This is because it is the registration in active debt that marks the passage of the administration of a certain tax debt, leaving the hands of the tax audit (RFB) and going to the care of the Attorney's Office (PGFN), in accordance with art. 2nd, 3rd, of Law No. 6,830/1980 (Tax Execution Law — LEF), as well as article 12 of Complementary Law No. 73/1993 (Organic Law of the Federal Attorney General's Office, of which the PGFN is part). Under the same conditions (discounts, installments, deadlines, etc.), the transaction with the IRS will normally tend to be more advantageous than the one made with the PGFN.