We continuously support clients in different industries, providing tax advice and tax planning and litigation services.
Our solid experience in tax law was acquired through our continuous work in tax advice, tax support services, legal opinions – including on the tax aspects of ownership restructuring processes and of investment acquisition transactions, as well as in tax due diligence, in submitting tax queries to the authorities and in special tax regimes. We boast a strong tax litigation practice both in administrative and in judicial proceedings. Our team conducts complex cases of strategic importance for clients in several industries.
Our clients are Brazilian and multinational companies that operate in several industries such as manufacturing, agribusiness, services, power, oil and gas, fintechs, technology, life sciences, real estate, hotels and consumer goods.
Our tax law services include mainly:
- Advice on M&A projects and on corporate and debt restructuring projects, including both domestic and cross-border transactions, proposing to the client structures and alternatives to optimize the taxation and carrying out due diligence processes;
- Tax planning and consulting Analysis of the taxation of to clients in many different industries, including energy, technology, mining, telecom, fintech, oil and gas – including the use of special customs regimes such as REPETRO and drawback –, advertising, logistics, life science, and agribusiness;
- Advice on transfer pricing, particularly on the review of their intercompany agreements and compliance with the new Brazilian regulations, including preparation of their TP files;
- Advice on potential impacts of the Tax Reform of Indirect Taxation;
- Use of federal, regional and local tax benefits and taxation of foreign trade activities;
- Advice to power companies, including large consumers and distributors, with emphasis on the gas and renewables segments;
- Advice on social security matters related to indemnification payments, stock option and profit-sharing programs;
- Advice on the recently implemented Qualified Domestic Minimum Top-up Tax (QDMTT) as part of the adoption of the OECD’s GloBE Rules (Pillar 2), as well as on transitional CbCR Safe Harbour analysis;
- Tax litigation both in administrative and in judicial proceedings at the federal, state and municipal levels, with emphasis on:
- Pioneering actions challenging unconstitutional and unlawful provisions found in new statutes or in new amendments to existing statutes;
- Administrative defense against federal, state or municipal notices of tax violation;
- Representing clients at higher courts located in Brasília (Administrative Board of Tax Appeals – CARF, Superior Court of Justice – STJ and Federal Supreme Court – STF);
- Preventive action in relation to and monitoring tax audits and procurement of tax compliance certificates.