Our Tax practice provides consulting and litigation services to domestic and foreign clients, individuals and legal entities, which are engaged in the most varied economic sectors. We advise clients in all aspects related to domestic and international taxation, focused on corporate reorganizations, project finance, infrastructure and energy (including renewables), capital and financial markets, and many other industries and sectors of practice.
Our professionals share the same commitment to excellence and practicality, focusing on providing an accurate and quick answer to our clients’ needs and always addressing their business peculiarities. To achieve these goals, the tax team is divided in groups focused on our clients’ industries and economic sectors.
We provide our clients with tailor-made solutions, including in respect to customs and social security matters, among which we can highlight:
TAX CONSULTING
- Tax planning and tax advisory on different domestic and cross-border transactions, including in respect to social security and customs matters, as well as tax consulting on the definition of the tax burden levied over different industries and sectors of practice.
- Tax planning and structuring on corporate reorganizations.
- Drafting legal opinions and memorandums addressing different tax matters.
- Assistance in respect to the correct fulfillment of ancillary obligations and tax returns.
- Assistance in obtaining tax and customs special regimes, and in negotiating tax incentives and adhering to tax installment agreements.
- Review of the methodologies adopted to calculate taxes and social security contribution, as well as consulting for complying with the Brazilian transfer pricing and CFC rules.
- Drafting, negotiation and follow-up of formal requests to reduce and/or eliminate Custom Duty on imports (including ex tarifario requests).
- Drafting of succession and matrimonial plans, including those intended to patrimonial protection, as well as assistance on the repatriation of values.
- Performing legal due diligences, as well as quantification of risks and exposition deriving from materialized tax liabilities.
TAX LITIGATION
- Drafting and follow-up of administrative defenses against tax deficiency notices and/or against decisions denying the homologation of tax setoffs.
- Management of materialized tax liabilities, including drafting and follow-up of judicial defenses/appeals against tax foreclosures.
- Drafting and follow-up of judicial measures either to reduce the tax burden or to recover overpaid/undue taxes.
- Drafting and follow-up of writs of mandamus intended to clear goods and/or restrain unfair and illegal actions practiced by tax/customs authorities.
- Assistance during tax inspections, including drafting of responses to notifications received by the taxpayer.
- Assessment of the risks of loss associated with tax cases in order to determine the need of booking provisions/reserves in one’s financials and the opportunity to adhere to incentive installment programs.
