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The quest for the real meaning of the constitutional expression "reasonable length of process" is an arduous, intricate and stormy task, insofar as the aforementioned "stony clause" comprises a relatively open concept and engraved by a certain subjectivity. In this sense, the present legal study aims to present relevant considerations regarding the content, scope and respective applicability of the "principle of reasonable length of process" in the administrative tax process. To do so, based on its constitutional provision (Article 5, paragraph LXXVIII) and doctrinal manifestations, we will examine relevant legislation governing the tax administrative process, legal norms included in the Code of Civil Procedure (Federal Law 13,105, dated 03/16/15) and decisions pronounced by the Superior Courts.

RAZOÁVEL DURAÇÃO DO PROCESSO CONTENCIOSO ADMINISTRATIVO TRIBUTÁRIO. CONSIDERAÇÕES RELEVANTES