What is suggested is the possibility of three main

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Oppositions in different phases of the PAF, namely a challenge to the release a which presupposes the existence of a paradigm that gives rise to its (un)feasibility. However, the possibility of embargoes for clarification in cases of omission, obscurity, contradiction and material error against each of the decisions made in the different procedural phases indicated above would also be considered, as well as the possibility of a monocratic judgment of the case's rapporteurs in the event of formal inadmissibility of the appeal filed, a decision subject to an appeal to be heard by the collegiate body.

Regarding the deadline, this would take place in business days, in line with what was capitulated in the with 30 days being the deadlines for the oppositions indicated in items "i", "ii" and "iii" above , and 10 days for the insurgencies described in items  also elsewhere. Another important issue to be regulated in a uniform manner must EX Mobile Phone Numbers be the declaration of the result of the trial in the event of a tie in the judging body. In our opinion, if there is a tie in the judging panel, the most equitable way to resolve the issue would be to maintain the required tax credit in full, respecting the presumption of validity of the administrative acts, as well as default interest, resulting from default on the maintained credit.



On the other hand, based on the values ​​that conform to the principle of in dubio pro reo , a tie would also result in the full cancellation of the fine imposed to the detriment of the person charged, since it is a requirement with a clear sanctioning nature. And, so that there is no doubt: in the event of a launch exclusively broadcast for the imputation of a sanction, with or without a pecuniary nature, the tie would be entirely in favor of the person sanctioned. Moving forward, a major difficulty observed in the field of practical implementation of PAFs concerns the incidence of article 15 of the CPC  that is, it arises from the resistance of administrative courts to subsidiarily apply the aforementioned Codex.