A TUTELA PENAL DA ORDEM TRIBUTÁRIA – POR DRª NATÁLIA MUCIDA ZANINI

Em princípio a arrecadação é um meio indispensável para que o Estado Social de Direito realize seus objetivos de justiça social distributiva. No entanto devem ser observados o princípio da equidade, onde cada indivíduo deve contribuir com uma quantia justa e o princípio da progressividade, no qual as alíquotas são majoradas à medida que são maiores os níveis de renda dos contribuintes.

Pode-se afirmar ainda a existência de uma derivação do princípio da equidade, qual seja o princípio da capacidade contributiva. Este por sua vez pode ser definido como a capacidade, do destinatário legal do tributo de suportar a carga tributária sem o depauperamento de sua riqueza, ao passo que do contrário, certamente prejudicadas estarão a igualdade, a propriedade e o não confisco.

A exigência tributária, portanto, possui a finalidade de auferir renda para financiar as atividades Estatais. O contribuinte, ao satisfazer tal pretensão estatal, realiza sua parcela de contribuição na consecução dos objetivos públicos. Esta é, a princípio, a função social dos tributos, qual seja permitir aos indivíduos, na medida de suas capacidades econômicas, que participem do custeio das atividades estatais de realização do bem comum.

Não obstante, a participação dos indivíduos com parcelas de seu patrimônio no custeio das atividades estatais não é o suficiente, é necessário ainda conforme anteriormente mencionado que as quotas a que cada um está obrigado reflitam suas possibilidades econômicas.

Assim, quem possuir maior capacidade contributiva deve participar com um montante pecuniário mais elevado do que aquele que possui patrimônio reduzido. Desse modo, a exigência fiscal adota critérios que levam em consideração a situação econômica do contribuinte ao qual irá ser imposto o gravame pecuniário. Apenas se a participação individual for equitativa é que se estará cumprindo a função social do tributo.

Em suma, a obtenção de receitas tem como escopo de municiar os cofres públicos, permitindo que o Estado execute suas obrigações constitucionais, objetivando, precipuamente, o bem estar comum.

A Constituição da República Federativa do Brasil de 1988 (CRFB/88) visou a garantia dos interesses individuais, mas dando especial ênfase à tutela dos interesses coletivos.
Desta forma, assegura o exercício dos direitos individuais e sociais no Título II, elencando os direitos e garantias fundamentais dos indivíduos, bem como determinando em seu art. 3º os objetivos fundamentais do Estado brasileiro. Assim dispõe:

Art. 3º Constituem objetivos fundamentais da República Federativa do Brasil:
I – construir uma sociedade livre, justa e solidária;
II – garantir o desenvolvimento nacional;
III – erradicar a pobreza e a marginalização e reduzir as desigualdades sociais e regionais;
IV – promover o bem de todos, sem preconceitos de origem, raça, sexo, cor, idade e quaisquer outras formas de discriminação.

Nesta ótica, há que se atentar à proteção do bem jurídico na esfera tributária, o que por sua vez seria a função institucional arrecadadora do Estado, ou ainda, o Erário Público.

Destarte, surge a incriminação dos crimes fiscais justificada na medida em que a impunidade da conduta de um contribuinte individual pode dar vazão a uma grande quantidade de condutas assemelhadas, a qual causa vultosos impactos sociais, econômicos e financeiros.

No entanto, para garantir o bem da sociedade, é necessário agir dentro de certos parâmetros de razoabilidade, necessidade e principalmente destacar a acuidade do princípio da dignidade da pessoa humana.

A tutela penal da ordem tributária visa à coerção de tipos penais e eventos que descapitalizem o Estado e outras Entidades a fim de garantir a ordem econômica e, consequentemente, a ordem tributária.

No entanto, antes da aplicação das sanções preceituadas pelo Direito Penal, é preciso que outras medidas sejam adotadas para que a regra que almeja o adequado desenvolvimento da sociedade seja espontaneamente cumprida.

É o que ocorre no caso da aplicação das regras tributárias. O Estado tem direito de exigir dos administrados determinados valores para manutenção da estrutura organizacional que garante a paz social. Quando as regras tributárias não são cumpridas pelo contribuinte, ou seja, quando ocorre o inadimplemento, é preciso indagar se há necessidade de interferência do Direito Penal para garantir a arrecadação tributária.

Para Luiz Flávio Gomes, o Direito penal, em suma, é a ultima ratio, isto é, o último instrumento que deve ter incidência para sancionar o fato desviado. (GOMES; MOLINA; BIANCHINI, 2007)
Destarte, o Direito Penal deverá agir subsidiariamente ao Direito Penal tributário, ou seja, quando houver a falência do sistema de controle social.

As condutas previstas nos crimes contra a ordem tributária estão estritamente vinculadas ao inadimplemento das obrigações tributárias (principal e acessória). Todavia, o Direito Tributário somente prevê em seu sistema positivado multas pecuniárias e restrições de direitos.

Não obstante, além das sanções pecuniárias e as restritivas de certos direitos, o legislador entendeu que o não cumprimento das referidas obrigações são também passíveis de sanções através de reprimendas determinadas pela legislação penal.

A sanção penal tributária pode se revestir de uma pena privativa de liberdade (reclusão ou detenção) ou de uma pena de multa. No entanto, para aplicação da punição na esfera penal é necessário que o agente infrator tenha praticado as condutas tipificadas, possuindo consciência e vontade de não pagar ou de reduzir o tributo ou ao menos assumindo o risco.

Assim em respeito ao princípio da intervenção mínima a criminalização de comportamentos só deve ocorrer quando se constituir meio necessário à proteção de bens jurídicos ou à defesa de interesses juridicamente indispensáveis à sociedade.

Destarte, o Direito Penal Tributário não deve servir de único instrumento de penalização, sob pena de banalizar-se a sua atuação que deve ser subsidiária, último remédio, última alternativa, a “ultima ratio”.

Desta forma, os crimes contra a ordem tributária, além da realização das condutas típicas, devem se consubstanciar de ofensa aos deveres tributários.
Enfim, é imprescindível que para a existência de um crime de ordem tributária esteja configurada a transgressão de um dever tributário, ilícito fiscal. Assim, havendo crime contra a ordem tributária, haverá dupla infração: penal e tributária. Contudo, poderá haver descumprimento de obrigação tributária (não pagamento de tributo ou pagamento insuficiente), sem que, no entanto, ocorra fato delituoso penal.

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