Post by account_disabled on Mar 4, 2024 1:36:16 GMT -6
Decree No. 11,249, published on November 11th, authored by the President of the Republic, regulates the "procedure for offering liquid and certain credits arising from a final and unappealable judicial decision" before the Union, conforming to the provisions set out in the article 100, §11, of the Constitution. Although the scope of the decree covers different modalities of use of these credits, this article will restrict its analysis to the impacts of the authorizatirinciple , will motivate the issuance of "act of the Attorney General of the National Treasury of the Ministry of Economy will provide for the use of liquid and certain credits referred to in this Decree for the settlement or amortization of debts registered in active debt of the Union, including in a settlement transaction of litigation" , under the terms of article 2, I and article 6 of this normative act.
Having made these reservations, in order to carry out a duly based analysis of what impacts such regulation will have on the complex of legal standards for tax transactions that currently exist , it is necessary to review and identify the specific standards and how they interact with each other to settle debts using net and certain credits EL Salvador Mobile Number List arising from a final court decision. Law No. 13,988/2020 Law No. 13,988/2020, the result of the legal conversion of the Legal Taxpayer Provisional Measure 899 of 2019, came to light as a paradigmatic change in the multi -door courthouse system [ 1] before the federal tax authorities, giving voice the old wording of the National Tax Code that provides for tax transactions as one of the mechanisms for extinguishing tax credits (article 156, III, of Law no.
In practical terms, the tax transaction is an "instrument for extinguishing the tax credit, having a formal character while its content corresponds to the other extinguishing causes, conveying remission, amnesty, compensation, cancellation of part of the credit and the commitment to pay or give payment" , as Leandro Paulsen [2] rightly states . This innovative consensual procedure, which allowed the Federal Tax Authorities to "sit at the table" to negotiate with taxpayers, respecting the Union's "judgment of opportunity and convenience" (article 1, §1, of Federal Law No. 13,988/2020), has been producing satisfactory results [3] , both in concluding agreements that allow for a solution to the fiscal crisis of debtor taxpayers, as well as for the Attorney General of the National Treasury in recovering debts considered irrecoverable or difficult to recover. With the evolution and practical implementation of this administrative negotiation procedure, Federal Law No.
Having made these reservations, in order to carry out a duly based analysis of what impacts such regulation will have on the complex of legal standards for tax transactions that currently exist , it is necessary to review and identify the specific standards and how they interact with each other to settle debts using net and certain credits EL Salvador Mobile Number List arising from a final court decision. Law No. 13,988/2020 Law No. 13,988/2020, the result of the legal conversion of the Legal Taxpayer Provisional Measure 899 of 2019, came to light as a paradigmatic change in the multi -door courthouse system [ 1] before the federal tax authorities, giving voice the old wording of the National Tax Code that provides for tax transactions as one of the mechanisms for extinguishing tax credits (article 156, III, of Law no.
In practical terms, the tax transaction is an "instrument for extinguishing the tax credit, having a formal character while its content corresponds to the other extinguishing causes, conveying remission, amnesty, compensation, cancellation of part of the credit and the commitment to pay or give payment" , as Leandro Paulsen [2] rightly states . This innovative consensual procedure, which allowed the Federal Tax Authorities to "sit at the table" to negotiate with taxpayers, respecting the Union's "judgment of opportunity and convenience" (article 1, §1, of Federal Law No. 13,988/2020), has been producing satisfactory results [3] , both in concluding agreements that allow for a solution to the fiscal crisis of debtor taxpayers, as well as for the Attorney General of the National Treasury in recovering debts considered irrecoverable or difficult to recover. With the evolution and practical implementation of this administrative negotiation procedure, Federal Law No.