A responsabilidade dos sócios e administradores pelos tributos devidos pela pessoa jurídica

Abstract

The central theme of this work concerns the analysis of tax liability and mostly passive approach to the tax liability prescribed in the tax code, concentrate on the factual circumstances of liability of shareholders, directors and general managers of legal persons for the payment of taxes against the claim of State for the collection of credit. In general debate will be brought to the tax relationship between these people and brought right to levy the tax authorities, considering the circumstances and limits within which the responsibility will belong, dissecting its nature and procedural consequences in accordance with the constitutional principles applicable and the understanding of case law and doctrine on the subject. In conclusion it seeks to contribute to the topic in order to prevent abuses by the tax authorities and introduce tools to the judiciary to act more closely in law enforcement and about the undeniable burden of proof of liability of persons acting on behalf of corporations, imposing limits on the pursuit of tax credit