Statute of Limitations in Portuguese and Brazilian Tax Law: Birds of a Feather Don’t Flock Together? 

Abstract

Time is of the essence; so it is in life as it is in law. Having this maxim in mind, this paper explores the con tours of the statute of limitations in the tax laws of Brazil and Portugal, uncovering the principles, policy choices, and practical implications that shape their application. By exploring the complex tapestry of legal norms, judicial interpretations, and scholarly commentary, we grapple with fundamental questions at the intersection of tax policy, constitutional principles, and the rule of law. Through this analysis, we aim to contribute to a deeper understanding of the critical role that the statute of limitations play in shaping the fairness, efficiency, and legitimacy of tax systems, providing insights that can inform the ongoing debate about the proper balance between the state’s revenue-raising powers and the taxpayer’s right to repose.

Keywords: Tax law, statute of limitations, tax principles, tax policy