Paula Teixeira da Cruz, the Minister of Justice, wants to review the tax procedure in order to resolve the "drama" of Fiscal and Administrative Courts, where the number of pending procedures is still extremely high.

Rogério Fernandes Ferreira has the opinion that there is no need to change the current law. The problem, states, "Tax authorities are absolutely under pressure with the revenue and have the guidelines to always appeal. However, they shouldn´t be prevented from appealing for losing three or four times".

The Partner and Founder of RFF & Associados, also takes the view that "the problem comes from upstairs. The ones who appeal make it because of superior guidance. I do not believe that, in abstraction, it can be talked about the existence of bad faith".