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The recent regulation of tax liability in economic groups by Complementary Law No. 214/2025 brought significant changes for companies and managers. Lawyer Maristela Ferreira de Souza Miglioli, from Ciari Moreira Advogados, analyzed for Link Jurídico how this regulation reinforces the courts’ understanding by requiring proof of irregular acts to establish joint tax liability.

According to Maristela, the Superior Court of Justice had already consolidated the position that the mere existence of an economic group is not enough to impose joint liability among companies. Now, the new legislation reaffirms this guideline, requiring the presence of misuse of purpose or patrimonial confusion for the sharing of tax debts to occur.

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