One of the biggest Brazilian problems in the tax field is legal insecurity, which leads the State and taxpayers to endless fights in the courts over the right to receive and the duty to pay taxes.

Tax litigation, as this dispute is called, continues to grow. Only at the federal level, the sum of the amounts under discussion or collection at the various levels of judgment and execution of debts exceeded half of GDP.

Despite the gravity of the situation, this problem has not received due attention from society, even in debates over tax reform.

ETCO has sought to contribute to changing this situation. One of the main actions in this regard was the hiring of the consultancy EY (Ernst & Young) to make a diagnosis of the tax litigation of the federal government. The result of this work was released at the end of last year.

The Institute now dedicates an edition of ETCO Magazine exclusively to the theme. In the past few months, the publication has heard 27 names involved in litigation from different angles: taxpayer representatives, lawyers, tax authorities, tax auditors, attorneys at the National Treasury, the Judiciary, non-governmental entities, economists.

The objective was to gather a wide range of views on the causes and proposed solutions to the problem.

Na presentation letter, ETCO's executive chairman, Edson Vismona, explains the Institute's initiative to focus on resolving tax litigation.

The magazine then brings a story about the main findings of the study carried out by EY.

Following, we publish a article by the Federal Revenue Secretary, José Tostes, written especially for the magazine, bringing the government's view of the problem.

The next story is a interview on the topic with the president of the ETCO Advisory Council, Everardo Maciel, who was secretary of the Federal Revenue during the eight years of the FHC government.

The magazine then brings a summary of causes and solutions pointed out by 25 interviewees, followed by the main excerpts from each interview. Respondents are:

• MARCOS LISBOA, president of Insper and former secretary of Economic Policy of the Federal Government.
• HELENO TORRES, professor of Tax Law at USP.
• NELSON MACHADO, director of the Center for Tax Citizenship (CCiF).
• REGINA HELENA COSTA, minister of the Superior Court of Justice and professor of Tax Law at PUC-SP.
• PAULO DOMINGUES, judge at the Federal Regional Court of the 3rd Region (TRF-3) and former president of the Association of Federal Judges of Brazil.
• PAULO CESAR CONRADO, federal judge, doctor of Tax Law at PUC-SP and professor at FGV Direito SP.
• MARCO BERTAIOLLI, federal deputy, was the rapporteur of the bill that converted the MP of the Legal Taxpayer into law, regulating the tax transaction.
• CÁSSIO BORGES, legal superintendent of the National Confederation of Industry (CNI).
• HELCIO HONDA, director of the Legal Department of the Federation of Industries of the State of São Paulo (Fiesp).
• ROBERTO QUIROGA, tax specialist at Mattos Filho, Veiga Filho, Marrey Jr and Quiroga Advogados.
• BENO SUCHODOLSKI, tax lawyer and member of the Legal Council of Fiesp.
• RAQUEL NOVAIS, partner in the tax area of ​​Machado Meyer Advogados.
• BRENO VASCONCELOS, partner at the firm Mannrich e Vasconcelos Advogados.
• HAMILTON DIAS DE SOUZA, partner at Dias de Souza Advogados Associados and member of the ETCO Advisory Board.
• VANESSA CANADO, tax expert, special advisor to Minister Paulo Guedes in the elaboration of the Federal Government's tax reform project.
• ADRIANA GOMES RÊGO, president of the Administrative Council for Tax Appeals (Carf).
• RITA BACCHIERI, tax specialist and vice president of Carf, where he acts as a taxpayer representative.
• PHELIPPE TOLEDO PIRES DE OLIVEIRA, Deputy Attorney General for Consultancy and Administrative-Tax Litigation at the Attorney General's Office of the National Treasury (PGFN).
• ADRIANA GOMES DE PAULA ROCHA, Deputy Attorney General of Consultancy and Strategy of the Judicial Representation of the PGFN.
• LEONARDO ALVIM, PGFN attorney and professor of Tax Law at Escola Superior Dom Helder Câmara, Belo Horizonte.
• JULIANA ARAÚJO, PGFN coordinator at TRF-3 and professor of Tax Law at FGV Direito SP.
• RITA DIAS NOLASCO, PhD in Law from PUC-SP and attorney at PGFN.
• MAURO SILVA, president of the National Association of Tax Auditors of the Federal Revenue of Brazil (Unafisco).
• LORREINE MESSIAS, economist and researcher on tax litigation.
• ZABETTA MACARINI GORISSEN, executive director of the Group of Applied Tax Studies (Getap).