Relativização da coisa julgada e segurança jurídica - questões polêmicas e a confiança legítima em matéria tributária

Abstract

This course work sought reflections on legal tax security in Brazil and its relativization based on the legal agenda of the General Repercussion themes 881 and 885 of the Federal Supreme Court and the Social Contribution on Net Profit. The research method used was inductive with a theoretical basis from basic literature and with a theoretical framework from Humberto Ávila and his work “Legal security between permanences, changes and achievements in tax law”. The research discusses the relativization of res judicata in tax matters and the issue of legitimate trust and legal certainty in Brazil, contributed to by legal uncertainty and procedural delays.