In Brazil, the PGFN (National Treasury Attorney General's Office) has launched an internal team dedicated to mapping out potential legal targets that could challenge the upcoming consumption tax reform, which is currently undergoing testing and slated for implementation in 2027. The head of the PGFN, Anelize Almeida, has indicated that the office may recommend to the President the filing of Direct Actions of Constitutionality (ADCs) with the Supreme Court if there is a surge of litigation across various regions of the country. Furthermore, the group is prepared to propose legislative changes to address controversial points that could lead to judicial disputes.

Almeida also mentioned that the group has already pinpointed at least five issues that have attracted scrutiny from lawyers, marking them as likely candidates for future legal challenges. This proactive stance is part of the PGFN's strategy to ensure that the new tax system, which aims to streamline and modernize Brazil's tax structure, can be implemented with minimal disruption from legal battles. The identification of these critical areas is essential as it can influence how the reform is received at various levels of government and amongst the public.

To facilitate this mapping process, the PGFN has been engaging in discussions with state and municipal prosecutors. This collaboration is vital to garner a comprehensive understanding of the legal landscape and potential areas of contention that could arise from the tax reform. This strategic approach not only aims to preempt challenges but also strives to foster clarity and predictability in the legal framework surrounding the new tax system, which is crucial for its successful implementation.