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Due to the precautionary measures authorized in the IDPJ, movable and immovable assets of individuals and legal entities that are, at least in the PGFN's understanding, related to the debtor taxpayer may have been blocked. Therefore, the moment of the transaction will be an opportunity to review this situation, excluding individuals and legal entities that are not related to the debtor taxpayer. In short, in the field of individual tax transactions there is no room for "tricks up your sleeve", only for "cards on the table"! And, more than that, good faith on both sides is fundamental.

After all, the taxpayer, to sign the transaction, will need to waive all defenses in ongoing proceedings, including defenses in Incidents of Disregard of the Legal Entity The tax transaction is a very important legal instrument Belgium Phone Number Data in our current procedural system and is an excellent way to resolve conflicts; however, the parties, whether lawyers or attorneys, or taxpayers themselves, must be prepared to seek an agreement, in the sense that everyone gives up something that they could have — if a final court decision were favorable to them — but choose not to have precisely, to end the process.



Thus if, on the one hand, the Attorneys need to justify, through a technical note, all the clauses that will form part of the transaction agreement (remembering that these clauses are public), on the other hand, the lawyers and the parties need to bring to the negotiation requests within the legal possibilities. Therefore, we conclude with our title: the path to obtaining a solution to the conflict involves the taxpayer presenting itself with the correct data and information and the Attorney's Office applying and using all legislative options to sign the transaction. Cards on the table for solutions to processes considered "unsolvable.
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