(IN)EFFICIENCY OF THE CURRENT MODEL OF ADMINISTRATIVE TAX PROCEDURE: ABSENCE OF A GENERAL LAW, ADMINISTRATIVE TAX COURTS, UNITARY AND PARITARY STRUCTURE OF APPELLATE BODIES

Abstract

This article analyzes the (in)efficiency of the current model of administrative tax proceedings in Brazil, characterized by the absence of a general law, the limited competence of administrative tax courts, and the parity-based structure of appellate bodies. By comparing the systems adopted in France, Italy, and England, the study discusses the feasibility of incorporating elements of technical specialization and greater effectiveness into the Brazilian context. The text also revisits the 1995 Draft Bill of the Administrative Tax Procedure Code and examines the innovations proposed by Bill No. 2,483/2022. It concludes that overcoming the current dysfunctions requires a new normative framework grounded in uniformity, specialization, and legal certainty.