In a judgment issued 11 April 2022, the Brazilian Supreme Federal Court ruled on whether the 2001 law adding the "sole paragraph" to Article 116 of the Brazilian National Tax Code is constitutional. The sole paragraph is a general anti-avoidance rule (GAAR), providing that the administrative authority may disregard acts or legal transactions carried out for the purpose of disguising the occurrence of a tax generating event or the nature of the elements that make up a tax obligation, subject to the procedures to be laid down in statutory law. Although such procedures have not been enacted, the GAAR has...