A Lei Complementar nº 225/2026 e o fim da extinção da punibilidade pelo pagamento nos crimes tributários em casos de devedor contumaz

This study examines the changes introduced by Complementary Law No. 225/2026 to the role of payment and installment agreements as grounds for extinguishing or suspending criminal liability in tax crimes. It focuses on the habitual tax debtor, defined by substantial, repeated and unjustified non-payment, and on the constitutional limits of transposing this administrative status into criminal proceedings. Through doctrinal legal research, based on bibliographic, legislative and case-law analysis, it addresses the former legal framework, the final assessment of the tax debt, the administrative classification procedure, the application of criminal law over time, the effects of subsequent payment, proof of intent and the culpability of managers. The study argues that the reform neither creates a new crime nor authorizes a presumption of criminal liability. Its constitutional application requires restrictive interpretation, a valid administrative decision, regular registration in Cadin, non-retroactivity of the harsher rule, individualized conduct and proportionality review.