Starting in the 1st century BCE, praetors began using their imperium to aid creditors affected by fraus creditorum, first by simple restitutio in integrum and a special interdict – interdictum fraudatorium.
Eventually, a separate action was created for this purpose – Actio Pauliana, specifically focused on reversing fraudulent transactions undertaken to defraud creditors.
Section VI, Chapter IV, Title I of Book III the Brazilian Civil Code of 2002 is dedicated to fraud against creditors, and describes a form of actio Pauliana related to insolvency.
It serves the same purpose as the Roman institution, but defines the circumstances in which it can be applied more clearly, including exactly when a transaction by a debtor is fraudulent and a presumption of bad faith for transfers between persons in close contact with one another.
[12][13][14][15] Articles 610 through 618 of the Portuguese Civil Code are titled "Paulian impugnation" (impugnação pauliana) and allow a creditor to attack transactions with third parties that jeopardise their debtor's solvency.