Law nº 15.690 of the municipality of São Paulo provides that the Attorney General of the Treasury of the Municipality of São Paulo may abstain from filing administrative appeal if the case concerns an issue already decided unquestionably by the higher courts (Federal Supreme Court and Superior Court of Justice).

Additionally, this law established the binding precedent institute for the Local Tax Board (Conselho Municipal de Tributos - “CMT”) grounded on decisions from higher courts. After analyzing the rule, one can say that the judgments in the city of São Paulo will be more time-efficient.

Moreover, it is important to mention that the new rules bring relevant changes to the procedural terms in the tax administrative proceedings of the municipality of São Paulo. Specifically with respect to the terms, the taxpayer will now have 15 days to file an appeal counted from the date the it is notified of the decision (the previous term was 30 days).

Still with respect to the time limits, the term for the Municipal Treasury to file a motion to modify a decision will be 15 days from the date of the judgment session (the previous term was 30 days).

(City Law /SP n. 15.690, Apr. 15, 2013, DOCidade, Apr. 16, 2013).