Overview
- The bill passed 436–2 with the Senate wording preserved, allowing it to proceed directly to presidential sanction.
- At the federal level, a devedor contumaz is defined as a taxpayer with unjustified debt over R$15 million exceeding 100% of known assets; states and municipalities use frequency-based criteria within a 12‑month window.
- Sanctions include bans on tax benefits and public bidding, ineligibility for judicial recovery, potential CNPJ inaptitude, inclusion in Cadin, and tighter limits on special installment regimes and penalty relief for repeat offenders.
- The government frames the measure as a tool against structured evasion and money laundering tied to sectors like tobacco, alcoholic beverages, and fuels, citing recent large operations and the Carbono Oculto probe.
- The package complements new cooperative compliance programs such as Confia and Sintonia, which offer self-regularization, risk ratings, and incentives for firms with strong tax compliance.