Customs penalties in Brazil: latest developments

Leonardo Macedo
Leonardo Macedo
Counsellor, Administrative Council of Tax Appeals (CARF), Brazil
Published 19 Nov 2025

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A recent court ruling distinguishes between two types of customs infractions: administrative (non-tax) and tax. An administrative infraction is subject to administrative extinctive prescription if not pursued within a three-year period (statutory limitation). A tax infraction is not subject to administrative extinctive prescription. This ruling requires Brazilian Customs to reclassify many customs penalties, which will have implications for the survival of those penalties.