The Brazilian tax system is extremely complex and insecure. And the rules change all the time. From 1988, when the Federal Constitution was enacted, until 2018, 16 Constitutional Amendments and more than 390 thousand tax rules were issued in the country.

The situation creates enormous legal uncertainty and is the source of a problem that is growing every year in the country: the disputes between the tax authorities and taxpayers. An research conducted in 2019 consultancy EY, at the request of ETCO, showed that the stock of tax litigation by the federal government alone is already equivalent to more than half of GDP (50,5%). In 2014, this index was 41,5%.

The complexity and insecurity of the tax system represent one of Brazil's main disadvantages in international competition for investments. This is shown by the Doing Business survey, carried out annually by the World Bank, which assesses the business environment of 190 countries in various aspects. In the 2020 edition, Brazil appears in 124th position in the general ranking - and 184th in terms of the quality of the tax payment system.

To contribute to the search for solutions to the problem, since 2019 we have chosen this theme as one of our priority flags. Because Brazil does not just need a change that makes our tax system more rational. It also needs a tax reform aimed at promoting legal certainty.