Análise da constitucionalidade e legalidade da averbação pré-executória no âmbito administrativo fiscal

Abstract

Analyze the impacts generated by the legislative change introduced by Law 13.606/2018, which went beyond the proposed objectives when it was published in 2002. This amendment not only created the "Rural Tax Regularization Program - PRR", but also conferred on the Attorney General of the National Treasury (PGFN) the right to be able to register the Certificate of Active Debt (CDA), as well as the rights of the taxpayers subject to attachment and lien, recording them unavailable. To discuss that the new legislation, which is ordinary, has not only instituted and regulated the "Rural Tax Regularization Program - PRR", but also erroneously conveys a matter related to the constriction of goods, of a tax nature, in disagreement with the Magna Carta of 1988, in addition to injuring death rights and constitutional guarantees.