Receita Federal Publishes First List of Repeat Tax Defaulters

Overview

• The Revenue Service published the first official list on June 24 after completing administrative procedures under Lei Complementar nº 225/2026, starting the law’s publicization phase.
• The law defines a repeat tax defaulter as a taxpayer with irregular tax debts of at least R$15 million that exceed known assets and show repeated nonpayment across specified periods within 12 months.
• The initial update names two cigarette companies and reports sector-level debts of more than R$25 billion in tobacco and more than R$30.6 billion in fuels, totaling over R$55 billion in identified liabilities.
• Listed firms face statutory penalties that include declaration of CNPJ inaptitude, inscription in Cadin, loss of tax benefits and prohibition on filing for judicial recovery, while the administrative process allows defenses and regularization options.
• The Receita launched an online portal explaining criteria, procedures and remediation paths, and said the measure targets structured nonpayment that distorts competition rather than firms with temporary financial distress.