Constitutional Challenges of the Specific Football Taxation Regime in the Context of Football Corporations

Abstract

This article explores the intricate relationship between Brazilian football and taxation, focusing on the normative and constitutional challenges surrounding the model of Football Public Limited Companies (SAFs) and the Specific Football Taxation Regime (TEF). The analysis begins with the tax immunity of nonprofit associations, as provided in Article 150, clause VI, item "c" of the Federal Constitution, addressing the legal criteria for its recognition and the conflicts arising from the restrictive stance of tax authorities. Subsequently, the study examines the SAF tax regime established by Law No. 14,193/2021, identifying its advances, such as fiscal simplification, but also its contradictions regarding constitutional principles, especially tax equality and contributory capacity. Finally, the research reflects on the need for normative adjustments to balance economic efficiency with constitutional compliance in the taxation of football in Brazil.