Brazil Tax Lawyer's Doctrine on Precatório Compensation Faces Revenue Service Resistance

A Brazilian tax lawyer has authored a doctrine supporting the use of federal precatórios to offset tax debts, following Constitutional Amendment 113/2021 and Decree 11.249/2022. Despite legal provisions, the revenue service continues to resist applying this compensation, creating administrative friction for taxpayers. This highlights a gap between legal framework and administrative practice, affecting over R$ 300 billion in precatórios.