Questão jurídica principal
Whether the companies were entitled to be exempted from paying an advance on costs in the VAT appeal proceedings.
Decisão extraída
No. A waiver of the advance on costs requires special reasons; insolvency or lack of funds of legal entities does not by itself justify exemption.
Fundamentação extraída
Under Art. 63(4) VwVG, advance costs are generally required. The companies were liquidated, bankrupt for lack of assets, or heavily overindebted, so they could not pay costs if they lost. That situation does not amount to special reasons, and legal entities cannot obtain de facto free proceedings via exemption from advances.