The tax litigation team at FCR LAW summarized the main points of the recent decisions of the Federal Supreme Court (STF) on Extraordinary Appeal (RE) 955.227 (Theme 885) and RE 949.297 (Theme 881), both related to the relativization of Res Judicata in tax matters.
The analysis evaluates, in the case of RE 955.227 (Theme 885), whether the STF’s decisions in incidental or diffuse control – for example in the judgment of an extraordinary appeal with general repercussion – cease the future effects of Res Judicata in tax matters.
In relation to RE 949.297 (Theme 881), FCR Law evaluates whether an STF decision in the so-called “concentrated or abstract control” – such as, for example, in the judgment of an ADI, ADO, ADC or ADPF – automatically ceases the effects of final and unappealable decisions of judges in concrete cases.
Read the full article and the impact of the STF decisions by clicking here!
More information at https://www.fcrlaw.com.br/
*Source: FCR Law