SMALL VALUE TAX CLAIM LAWSUITS: STF’S 1.184 THEME AND CNJ’S 547 RESOLUTION AND IT’S APPLICATION BY PARANÁ’S STATE COURT OF JUSTICE

Abstract

This study focuses on Theme No. 1.184 of the Federal Supreme Court (STF) and Resolution No. 547 of the National Council of Justice (CNJ), which regulates the extinction of small-value tax enforcement lawsuits, and its application by Paraná State Court of Justice (TJPR). The paper was carried out using the hypothetical-deductive method and the technique of bibliographical and documentary research into legislation and other regulations on the subject. TJPR’s jurisprudence on the matter, since the Resolution was published, was also analyzed. It was possible to see that the subject has been studied by CNJ since 2010. However, it was only in 2024 that directives about it emerged at a national level, through the regulations that give this work its name. TJPR began to apply them, reaffirming the texts and clarifying any doubts, until the Circular Letter No. 58/2024 of the DCJ-DMAP was published on August 14^th, 2024. The document aimed to standardize case law on the subject, and did so through various statements. Some simply reinforced the texts, while others set out the TJPR's understanding of some related particularity. It was possible to conclude that STF Theme No. 1.184 and CNJ Resolution No. 547 came about after the body had been paying attention to the subject for more than a decade and, despite criticism of their legitimacy, were widely applied and regulated by the TJPR, which was concerned with standardizing case law on the subject and seems to have succeeded in this task.