Expert Analysis

When Brazilian tax auditors intend to hold third parties liable for a legal entity's tax debts, they issue a notice of joint tax liability (Termo de Sujeição Passiva Solidária) to the company's partners. In some cases, the notice will simply set out the name of the partner or manager and give notice of the assessment of taxes against the company, "for the purposes of article 135 of the National Tax Code". The usual explanation is that a notice of joint tax liability will be issued to partners responsible for the management of a company whenever the tax assessment includes the increased fine that the tax authorities will impose when they believe that fraud was committed.

Milen Raikov

Luc De Broe

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