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1Under the National Tax Code (Código Tributário Nacional — CTN, Lei nº 5.172/1966), regarding tax obligations and their legal classification, which of the following statements correctly characterizes an accessory tax obligation (obrigação tributária acessória)?
A.An accessory obligation has a pecuniary nature from its inception and arises exclusively from a formal administrative assessment (lançamento de ofício).
B.An accessory obligation arises from tax legislation and entails positive or negative performances in the interest of tax assessment or inspection; its breach automatically converts it into a principal obligation regarding the pecuniary penalty.
C.An accessory obligation is legally subordinate to a pre-existing principal obligation, meaning that the nullity of the principal tax debt automatically extinguishes the accessory obligation.
D.An accessory obligation can only be created by Complementary Law (Lei Complementar), strictly following the principle of formal statutory legality (legalidade estrita).
Explanation: Pursuant to Article 113, §2º and §3º of the CTN, an accessory tax obligation arises from the broad body of tax legislation (legislação tributária) and consists of positive acts (e.g., filing declarations, issuing invoices) or negative acts (e.g., tolerating fiscal audits) in the interest of tax administration. Under §3º, the non-compliance with an accessory obligation converts it by operation of law into a principal obligation as to the resulting pecuniary penalty (multa).
2A corporate taxpayer correctly calculates its corporate income tax (IRPJ) and reports it via a formal federal tax return (DCTF), but fails to make the corresponding payment on the statutory due date. According to the CTN and the settled jurisprudence of the Superior Court of Justice (STJ Súmula 436), what legal consequence arises regarding the constitution of the tax credit?
A.The tax authority must issue a formal administrative tax assessment notice (auto de infração) to establish the tax credit before registering the debt in the Union's Active Debt (Dívida Ativa da União).
B.The formal declaration by the taxpayer via DCTF constitutes the tax credit, rendering any further administrative assessment unnecessary and enabling immediate registration in Dívida Ativa and subsequent fiscal execution.
C.The tax credit remains suspended until the administrative review period of 30 days expires under Decree 70.235/1972.
D.The declaration alone constitutes only an accessory debt, requiring an ex officio assessment (lançamento de ofício) within the 5-year decadence period to enforce the principal debt.
Explanation: According to STJ Súmula 436 and CTN Art. 150, the submission of a formal tax return (such as DCTF, GFIP, or DCTFWeb) declaring the tax debt is sufficient to constitute the tax credit. In the event of non-payment, the National Treasury is not required to issue a formal deficiency notice (auto de infração) or open an administrative tax proceeding; the debt may be directly enrolled in Dívida Ativa da União and enforced via judicial tax execution (Execução Fiscal).
3A company subject to PIS/COFINS under the non-cumulative regime made partial monthly payments in fiscal year 2020, but improperly excluded several taxable revenue streams from its tax base without committing willful fraud, bad faith, or simulation. The Federal Revenue Service intends to assess the outstanding deficiency in 2026. Under the CTN and STJ Repetitive Precedents (Tema 163 and Súmula 555), what is the applicable decadence rule and term for the tax authority to launch the tax credit?
A.The decadence term is governed by Article 173, I of the CTN, counting 5 years from the first day of the fiscal year following the year in which the assessment could have been made.
B.The decadence term is governed by Article 150, §4º of the CTN, expiring 5 years from the occurrence of the taxable event (fato gerador), because partial advance payment was made without fraud.
C.The decadence period is 10 years, combining the 5-year tacit approval period under Article 150, §4º with the 5-year ex officio period under Article 173, I of the CTN ('tese dos cinco mais cinco').
D.The decadence period is interrupted by the initiation of any internal audit procedure, giving the tax authority an additional 5 years from the audit notification.
Explanation: Under settled STJ jurisprudence (Tema Repetitivo 163 / REsp 973.733/SC), when a tax subject to lançamento por homologação has an advance payment (even if partial) and there is no evidence of fraud, willful misconduct (dolo), or simulation, the decadence rule is strictly governed by Art. 150, §4º of the CTN. The 5-year period begins on the date of the taxable event (fato gerador). Article 173, I of the CTN applies only when there is zero advance payment or proven fraud/simulation.
4Under Article 151 of the CTN and the jurisprudence of the STJ and STF, which of the following events constitutes a lawful cause for the suspension of the enforceability of a tax credit (suspensão da exigibilidade do crédito tributário)?
A.The provision of a bank surety bond (fiança bancária) or judicial insurance bond (seguro garantia) during administrative collection.
B.The deposit of the full monetary amount of the contested tax debt in cash in a judicial proceeding.
C.The granting of a debt installment plan (parcelamento) after the expiration of the statutory limitation period (prescrição).
D.The filing of a simple administrative request for reconsideration that is not formally classified as a defense or appeal under Decree 70.235/1972.
Explanation: Under Article 151, II of the CTN and STJ Súmula 112, the judicial deposit suspends the enforceability of the tax credit only if it is integral and in cash (em dinheiro). Other causes under Art. 151 include moratória (I), administrative complaints and appeals under governing procedural laws (III), preliminary injunctions in mandado de segurança (IV), provisional tutela in other judicial actions (V), and parcelamento (VI).
5A corporate debtor proposes to settle its federal tax liabilities registered in Dívida Ativa da União through payment in kind with real estate (dação em pagamento em bens imóveis). In light of Article 156, XI of the CTN (introduced by LC 104/2001) and Federal Law nº 13.259/2016, what are the statutory requirements for this modality of tax extinction?
A.Dação em pagamento operates automatically upon the taxpayer's unilateral deed registration, regardless of National Treasury acceptance.
B.It requires authorization by ordinary federal law, must cover the entirety of the debt (or be supplemented by cash), is restricted to real property free and clear of any encumbrances, and requires prior administrative evaluation and acceptance by the PGFN.
C.Dação em pagamento is permitted exclusively for municipal and state taxes, being prohibited for federal tax debts under the constitutional reserve of monetary currency (moeda corrente).
D.It allows the transfer of shares and movable goods on an equal standing with real estate, without requiring any formal statutory valuation.
Explanation: Under CTN Art. 156, XI and Lei nº 13.259/2016 (regulated by PGFN ordinances), dação em pagamento de bens imóveis is an autonomous mode of tax credit extinction. It requires explicit statutory regulation, applies strictly to real property unencumbered by liens (livre e desembaraçado), requires prior appraisal by federal authorities (such as SPU or Caixa Econômica Federal), and depends on discretionary administrative acceptance and utility determination by the PGFN.
6In a judicial tax execution (Execução Fiscal) filed by the National Treasury Attorneys (PGFN), the judicial order directing service of process (despacho que ordena a citação) was issued by the federal judge 4 years and 11 months after the definitive constitution of the tax credit. However, actual service of process on the corporate executive was effected 8 months later due to judicial registry delays. According to Article 174, parágrafo único, I of the CTN (redação dada pela LC 118/2005) and STJ Súmula 106, has the tax credit prescribed?
A.Yes, because the five-year limitation period is interrupted exclusively by actual physical personal service (citação válida) on the debtor.
B.No, because under LC 118/2005 the limitation period is interrupted by the judicial order directing citation, which retroacts to the date of filing the execution, and delays attributable solely to the court machinery do not harm the creditor.
C.Yes, because the retroactive effect of citation applies exclusively to civil execution proceedings under the CPC, not to tax enforcement under the CTN.
D.No, because the National Treasury enjoys an automatic and indefinite suspension of prescription until the debtor is physically located.
Explanation: Under Article 174, parágrafo único, I of the CTN (amended by LC nº 118/2005), the five-year statute of limitations (prescrição) is interrupted by the judicial order ordering service of process (despacho que ordena a citação). Pursuant to Article 240, §1º of the CPC and STJ Súmula 106, the interruption retroacts to the date the judicial execution was filed, and procedural delays caused exclusively by judicial registry backlogs cannot be penalized against the executing Treasury.
7Regarding the exclusion of the tax credit (exclusão do crédito tributário) under the National Tax Code, which of the following rules accurately reflects the legal regime of tax exemptions (isenções) and tax amnesties (anistias) under CTN Articles 111, 175, 177, and 180?
A.An amnesty (anistia) excludes the obligation to pay the principal tax debt as well as all ancillary administrative penalties.
B.An exemption (isenção) dispenses the taxpayer from complying with accessory tax obligations, such as issuing invoices and filing declarations.
C.Tax amnesties apply exclusively to infractions committed prior to the enactment of the law granting them, and cannot be granted for acts committed with fraud, willful deceit (dolo), or collusion.
D.Legislation granting tax exemptions or amnesties must be interpreted extensively in favor of taxpayers under the principle of in dubio pro reo.
Explanation: Under Article 180, I and II of the CTN, an amnesty (anistia) applies strictly to infractions committed prior to the enactment of the granting statute, and it cannot extend to acts performed with fraud, willful misconduct (dolo), simulation, or collusion. Furthermore, under CTN Art. 175, parágrafo único, exclusion of the tax credit does not relieve the taxpayer from fulfilling accessory obligations, and under CTN Art. 111, laws granting exemption or amnesty must be interpreted literally (restritivamente).
8An investor acquires a commercial building at a judicial public auction (arrematação em hasta pública). Prior to the auction, the property had accrued R$ 500,000 in unpaid Urban Property Tax (IPTU) and Federal Rural/Urban municipal fees. According to Article 130, parágrafo único of the CTN and consolidated STJ jurisprudence, what is the tax liability of the successful auction purchaser (arrematante)?
A.The purchaser becomes personally and jointly liable for all pre-existing tax debts attached to the real estate, regardless of the auction price.
B.The tax liability subrogates onto the purchase price paid at the auction (sub-rogação sobre o respectivo preço), meaning the purchaser acquires original title free of pre-existing tax debts.
C.The purchaser must pay 50% of the accrued tax debt, with the remaining 50% charged to the bankrupt estate or former owner.
D.The tax credit is automatically annulled by the judicial sale, and the municipality loses any right to collect from the auction proceeds.
Explanation: According to Article 130, parágrafo único of the CTN and settled STJ jurisprudence (e.g., REsp 1.299.403/PR), in the case of judicial auction (arrematação em hasta pública), pre-existing property taxes (impostos cujo fato gerador seja a propriedade, posse ou domínio) subrogate directly onto the auction price deposit (sub-rogação sobre o preço). Consequently, the purchaser acquires the asset clean of tax encumbrances, and the tax authority must satisfy its credit from the sale proceeds.
9A healthy manufacturing corporation purchases an isolated productive business unit (Unidade Produtiva Isolada — UPI) of a debtor company in a court-approved Judicial Restructuring (Recuperação Judicial), in accordance with Law nº 11.101/2005. The debtor company had R$ 10 million in federal tax debts. Under Article 133, §1º and §2º of the CTN, does the purchaser succeed to the tax liabilities of the debtor?
A.Yes, because Article 133 of the CTN imposes strict joint and several liability on any acquirer of a commercial establishment or business bottom (fundo de comércio).
B.No, the purchaser of an isolated productive unit in a judicial recovery or bankruptcy sale does not succeed to the tax liabilities of the seller, provided the buyer is not an insider, relative, or shareholder of the debtor.
C.Yes, but the buyer's liability is subsidiary and limited only to social security contributions owed to the INSS.
D.No, but only if the Federal Revenue Service and PGFN were unanimous in voting in favor of the judicial restructuring plan at the Creditors' Meeting.
Explanation: Under Article 133, §1º, II of the CTN (amended by LC 118/2005) and Article 60, parágrafo único of Law 11.101/2005, the acquisition of an Isolated Productive Unit (UPI) in a judicial restructuring or bankruptcy proceeding does not transfer tax liabilities (não há sucessão tributária). This exemption from tax succession does not apply only if the purchaser is a partner, relative, or entity under common corporate control (CTN Art. 133, §2º).
10The National Treasury Attorneys (PGFN) seek to hold the managing director (sócio-administrador) of a limited liability company (sociedade limitada) personally liable for unpaid federal taxes solely on the grounds that the company defaulted on its tax payments due to financial distress. According to STJ Súmula 430 and CTN Article 135, III, is this redirection (redirecionamento) of the fiscal execution legally valid?
A.Yes, because failure to pay taxes on time constitutes a per se statutory infraction under CTN Art. 135, creating strict personal liability for all statutory managers.
B.No, because the mere default or non-payment of a tax (mero inadimplemento) does not constitute an act with excess of powers or violation of law/articles of association, and cannot by itself justify personal liability under CTN Art. 135, III.
C.Yes, provided the company does not possess sufficient real estate registered in its name to guarantee the tax debt.
D.No, because managing directors of limited liability companies can never be held personally liable for tax debts under any circumstances.
Explanation: According to STJ Súmula 430 and Tema Repetitivo 97, the mere default on tax payments (inadimplemento da obrigação tributária) does not, by itself, generate personal liability for the managing partner under Article 135, III of the CTN. To redirect the tax execution to the manager's personal assets, the Treasury must demonstrate specific acts performed with excess of mandate (excesso de poderes) or in direct violation of the law or corporate charter (infração à lei, contrato social ou estatuto), such as irregular dissolution (Súmula 435).
About the Procurador da Fazenda PGFN Exam
The Concurso Público para Procurador da Fazenda Nacional is the specialized federal tax litigation appointment process organized by the PGFN and Cebraspe under Lei Complementar nº 73/1993 and Lei nº 11.457/2007. PGFN attorneys represent the Federal Union in tax and fiscal litigation, administer the registration and collection of the Federal Active Debt (Dívida Ativa da União), and provide legal counsel to the Ministry of Finance.
Assessment
Six phases: prova objetiva (100 five-option MCQs, 5 hours, worth 100 points — Grupo I 34, Grupo II 34, Grupo III 32); three discursive papers (a parecer on Grupo I, a peça judicial on Grupos I and II, and a dissertação on Grupos I and III, each with three accompanying questions); inscrição definitiva; prova oral; sindicância de vida pregressa; and avaliação de títulos.
Time Limit
5 hours (300 minutes)
Passing Score
Minimum 50% of the points in each of the three discipline groups
Exam Fee
R$ 180,00 (Procuradoria-Geral da Fazenda Nacional (PGFN) / AGU / Cebraspe)
Procurador da Fazenda PGFN Exam Content Outline
40%
Grupo I (34 questões): Direito Tributário, Financeiro e Econômico e da Seguridade Social
CTN rules, federal taxes (IR, IPI, IOF, ITR, PIS/COFINS), Dívida Ativa da União, Execução Fiscal (Lei 6.830/1980), and tax transactions.
30%
Grupo II (34 questões): Direito Processual Civil, Civil, Empresarial, Penal e Processual Penal, do Trabalho e Processual do Trabalho
Constitutional limits on taxation, CARF procedure, administrative tax defense, tax mandados de segurança, and precedents.
30%
Grupo III (32 questões): Direito Constitucional, Administrativo e Internacional Público
Tax liability in bankruptcy, corporate veil piercing (Art. 135 CTN), social security contributions, and transfer pricing (Lei 14.596/2023).
How to Pass the Procurador da Fazenda PGFN Exam
What You Need to Know
- Passing score: Minimum 50% of the points in each of the three discipline groups
- Assessment: Six phases: prova objetiva (100 five-option MCQs, 5 hours, worth 100 points — Grupo I 34, Grupo II 34, Grupo III 32); three discursive papers (a parecer on Grupo I, a peça judicial on Grupos I and II, and a dissertação on Grupos I and III, each with three accompanying questions); inscrição definitiva; prova oral; sindicância de vida pregressa; and avaliação de títulos.
- Time limit: 5 hours (300 minutes)
- Exam fee: R$ 180,00
Keys to Passing
- Work through all 100 available questions
- Review every answer and explanation
- Track weak areas and revisit them
- Use our AI tutor for tough concepts
Frequently Asked Questions
What is the primary role of a Procurador da Fazenda Nacional?
A Procurador da Fazenda Nacional is responsible for representing the Federal Union in tax and financial lawsuits, collecting federal fiscal debts (Dívida Ativa da União), and advising the Ministry of Finance on fiscal policies.
What is the passing score for the PGFN objective examination?
There is no single overall cut. Item 8.13.4 of Edital nº 1 – PGFN/2022 requires at least 50% of the points in each of the three discipline groups (Grupo I with 34 questions, Grupo II with 34, Grupo III with 32). Scoring below 50% in any one group eliminates the candidate regardless of the total.
What forensic practice requirement applies to the PGFN competition?
Candidates must have an active OAB registration and at least 2 years of verified forensic legal practice (prática forense) completed prior to registration.