A report issued by the Superior Court of Justice (STJ) on the impacts of the tax reform on the Judiciary indicates that the new taxes—IBS (Goods and Services Tax) and CBS (Contribution on Goods and Services)—have the potential to triple the current volume of tax litigation.

At the STJ alone, approximately 63,000 tax cases were filed in 2024, around 19,000 of which involved taxes that will be replaced (PIS, Cofins, IPI, ICMS, and ISS). According to the Court, the tax reform has the potential to raise judicial tax litigation to unprecedented levels, “exhausting the resources of the Judiciary.”

The report also addresses which courts should have jurisdiction over cases involving the new taxes and diverges from the proposal presented by the Office of the Attorney General of the Union (AGU). Rather than combining state and federal judges in specialized courts, the justices argue that this responsibility should rest exclusively with the Federal Judiciary.