The orderer in the import declarations would be proof that he was the real importer (legal recipient), and that he had used the importing company as a facilitator of the procedures necessary for the import and clearance of the goods [8] . This allegation is even more incoherent, since, once the custom import has been carried out, the ordering party will always appear on the Import Declaration as the future recipient of the goods, including under the name "Purchaser of the Goods", as per guidance from the Federal Revenue Service itself and News Siscomex Importation.
Another important point raised by the judges was the lack of proof of payments made to the importing company. In these cases, it was argued that the absence of such documents did not allow the conclusion that the operations assessed were, in fact, domestic EX Mobile Phone Numbers acquisition of merchandise imported to order. Consequently, the reclassification of the operation for import on account and order was accepted [10] . Finally, it is worth highlighting that in several decisions it was pointed out that the lack of proof of the negotiations between the ordering party and the importing company would lead to the conclusion that there was simulation regarding the nature of the contract signed.
In other words, in such cases there was a reversal of the burden of proof to require the defendant to prove that he was, in fact, merely ordering the goods, and not the importer. According to these judgments, the absence of proof of the good faith and honesty of the defendant would provide strong evidence to allow the reclassification of the operation as importation on account and order [11] . It is concluded, therefore, that the judgment on Theme 520 does not resolve all the legal uncertainty that hangs over the issue.