Procurador da Fazenda PGFN Practice Questions - Concurso Público para Procurador da Fazenda Nacional (PGFN) Exam - Procurador da Fazenda PGFN Practice Questions - Concurso Público para Procurador da Fazenda Nacional (PGFN) Exam

Question 1

Under the National Tax Code (Código Tributário Nacional — CTN, Lei nº 5.172/1966), regarding tax obligations and their legal classification, which of the following statements correctly characterizes an accessory tax obligation (obrigação tributária acessória)?

An accessory obligation has a pecuniary nature from its inception and arises exclusively from a formal administrative assessment (lançamento de ofício). An accessory obligation arises from tax legislation and entails positive or negative performances in the interest of tax assessment or inspection; its breach automatically converts it into a principal obligation regarding the pecuniary penalty. An accessory obligation is legally subordinate to a pre-existing principal obligation, meaning that the nullity of the principal tax debt automatically extinguishes the accessory obligation. An accessory obligation can only be created by Complementary Law (Lei Complementar), strictly following the principle of formal statutory legality (legalidade estrita).

Correct Answer:

An accessory obligation arises from tax legislation and entails positive or negative performances in the interest of tax assessment or inspection; its breach automatically converts it into a principal obligation regarding the pecuniary penalty.

Question 2

A corporate taxpayer correctly calculates its corporate income tax (IRPJ) and reports it via a formal federal tax return (DCTF), but fails to make the corresponding payment on the statutory due date. According to the CTN and the settled jurisprudence of the Superior Court of Justice (STJ Súmula 436), what legal consequence arises regarding the constitution of the tax credit?

The tax authority must issue a formal administrative tax assessment notice (auto de infração) to establish the tax credit before registering the debt in the Union's Active Debt (Dívida Ativa da União). The formal declaration by the taxpayer via DCTF constitutes the tax credit, rendering any further administrative assessment unnecessary and enabling immediate registration in Dívida Ativa and subsequent fiscal execution. The tax credit remains suspended until the administrative review period of 30 days expires under Decree 70.235/1972. The declaration alone constitutes only an accessory debt, requiring an ex officio assessment (lançamento de ofício) within the 5-year decadence period to enforce the principal debt.

Correct Answer:

The formal declaration by the taxpayer via DCTF constitutes the tax credit, rendering any further administrative assessment unnecessary and enabling immediate registration in Dívida Ativa and subsequent fiscal execution.

Question 3

A company subject to PIS/COFINS under the non-cumulative regime made partial monthly payments in fiscal year 2020, but improperly excluded several taxable revenue streams from its tax base without committing willful fraud, bad faith, or simulation. The Federal Revenue Service intends to assess the outstanding deficiency in 2026. Under the CTN and STJ Repetitive Precedents (Tema 163 and Súmula 555), what is the applicable decadence rule and term for the tax authority to launch the tax credit?

The decadence term is governed by Article 173, I of the CTN, counting 5 years from the first day of the fiscal year following the year in which the assessment could have been made. The decadence term is governed by Article 150, §4º of the CTN, expiring 5 years from the occurrence of the taxable event (fato gerador), because partial advance payment was made without fraud. The decadence period is 10 years, combining the 5-year tacit approval period under Article 150, §4º with the 5-year ex officio period under Article 173, I of the CTN ('tese dos cinco mais cinco'). The decadence period is interrupted by the initiation of any internal audit procedure, giving the tax authority an additional 5 years from the audit notification.

Correct Answer:

The decadence term is governed by Article 150, §4º of the CTN, expiring 5 years from the occurrence of the taxable event (fato gerador), because partial advance payment was made without fraud.

Question 4

Under Article 151 of the CTN and the jurisprudence of the STJ and STF, which of the following events constitutes a lawful cause for the suspension of the enforceability of a tax credit (suspensão da exigibilidade do crédito tributário)?

The provision of a bank surety bond (fiança bancária) or judicial insurance bond (seguro garantia) during administrative collection. The deposit of the full monetary amount of the contested tax debt in cash in a judicial proceeding. The granting of a debt installment plan (parcelamento) after the expiration of the statutory limitation period (prescrição). The filing of a simple administrative request for reconsideration that is not formally classified as a defense or appeal under Decree 70.235/1972.

Correct Answer:

The deposit of the full monetary amount of the contested tax debt in cash in a judicial proceeding.

Question 5

A corporate debtor proposes to settle its federal tax liabilities registered in Dívida Ativa da União through payment in kind with real estate (dação em pagamento em bens imóveis). In light of Article 156, XI of the CTN (introduced by LC 104/2001) and Federal Law nº 13.259/2016, what are the statutory requirements for this modality of tax extinction?

Dação em pagamento operates automatically upon the taxpayer's unilateral deed registration, regardless of National Treasury acceptance. It requires authorization by ordinary federal law, must cover the entirety of the debt (or be supplemented by cash), is restricted to real property free and clear of any encumbrances, and requires prior administrative evaluation and acceptance by the PGFN. Dação em pagamento is permitted exclusively for municipal and state taxes, being prohibited for federal tax debts under the constitutional reserve of monetary currency (moeda corrente). It allows the transfer of shares and movable goods on an equal standing with real estate, without requiring any formal statutory valuation.

Correct Answer:

It requires authorization by ordinary federal law, must cover the entirety of the debt (or be supplemented by cash), is restricted to real property free and clear of any encumbrances, and requires prior administrative evaluation and acceptance by the PGFN.

Question 1

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Prepare with the Procurador da Fazenda PGFN Practice Questions - Concurso Público para Procurador da Fazenda Nacional (PGFN) Exam practice quiz. This question bank includes 100 questions covering federal, article, legal, statutory, and corporate. Use it to review important concepts, identify knowledge gaps, and build confidence for the related exam, course, or assessment.

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Procurador da Fazenda PGFN Practice Questions - Concurso Público para Procurador da Fazenda Nacional (PGFN) Exam

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