The majority of the Brazilian Supreme Court (STF) considered as a crime the failing to pay the ICMS already declared. In the opinion of Candido Martins partner Tatiana Del Giudice Cappa Chiaradia the understanding is sad news and is at odds with concepts of tax law and criminal law.
Check out the article from Revista Consultor Jurídico (ConJur) at https://lnkd.in/dv47BzU