TITLE:
Tax Reform on Consumption in Brazil: The Need for Change
AUTHORS:
Marcelo Ferraz Pinheiro
KEYWORDS:
Tax Reform on Consumption, Complexity of Rules, Extensive Tax Litigation, Tax Competition
JOURNAL NAME:
Beijing Law Review,
Vol.16 No.4,
December
9,
2025
ABSTRACT: This article provides a brief analysis of the reasons that led Brazil to pursue tax reform on consumption, highlighting the peculiarities of the Brazilian tax system through: i) the high complexity of complying with tax legislation; ii) extensive tax litigation; and iii) tax competition among the federated entities seeking to attract private investment and increase revenue. The methodological approach adopted combines pragmatic and zetetic research, drawing upon Brazilian and foreign legal scholarship and analyzing precedents from the Brazilian Supreme Federal Court. The development of this study necessarily entails questioning and criticizing classical tax law dogmatics in order to adapt it to the new challenges and demands to which it is constantly exposed. By situating the Brazilian experience, the article also offers insights into the broader international debate on VAT reforms and federal systems.