Contencioso cível e arbitragem

Tax Law

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We operate in a differentiated and personalized way, offering solutions for tax advisory, and litigation matters, having as premises the constant improvement of our clients’ experience with the services provided and delivery of high value-added results.

Based on the extensive experience of our professionals in serving medium and large companies in the renewable energy (solar and wind), automotive, pharmaceutical, construction, infrastructure, oil and natural gas segments, we conduct tax issues strategically in order to obtain a more agile and efficient return, as required by the market

Tax Advisory Services

We provide personalized tax advice to Brazilian and international companies, focusing on tax efficiency and compliance, including corporate reorganization, mergers, acquisitions, and investments in general.

Our team stands out for its multidisciplinary vision and for always seeking to understand the client’s business closely, adding solutions with economic, financial, and accounting thought, such as:

  • Advice on understanding and structuring the taxation of legal entities engaged in all Brazilian or international business activities.
  • Advice and guidance to domestic and foreign investors in opening new businesses.
  • Guidance in tax and corporate planning projects, with the solutions appropriate for each business model.
  • Planning and obtaining special arrangements at the federal and state levels, with the aim of increasing competitive advantage by reducing the tax burden and eliminating inefficiencies related to the accumulation of tax credits.
  • Practice in M&A transactions from conducting due diligence to mapping tax risks to structuring possible business scenarios.

In this context, our main achievements are:

  • Study and mapping of the entire ICMS-ST chain of a multinational in the cosmetics sector to gain a competitive advantage.
  • Planning and conducting tax efficiency simulations in the installation of a plastics manufacturing facility in the Manaus Free Trade Zone.
  • Investment feasibility study and obtaining tax benefits in various Brazilian states for companies importing goods.
  • Review of the tax burden and planning of corporate changes with a view to tax savings in a group of companies in the food sector.

Administrative Litigation

Strong performance in Federal, State, and Municipal inspections with extensive experience in proposing personalized administrative defenses and oral arguments in administrative courts.

The experience of our professionals in accounting and tax operational issues in general facilitates dialog with the internal teams of the companies dedicated to attendance to inspections and provides a better result for the client’s business, through:

  • Detailed analysis of tax notices to define a strategy to protect the interests of companies.
  • Preparation of the clarifications to be submitted to the tax authorities.
  • Simulation in advance of possible amounts in the event of an assessment.
  • Filing of defenses and appeals in all administrative instances and conducting oral arguments in court.

In this context, our main achievements are:

  • Cancellation of an Infraction Notice issued against a metallurgical company in the amount of R$ 36 million, involving a fine linked to social security offsets.
  • Exclusion of the liability of partners with the Brazilian Federal Revenue Service, whose debt amounted to
    R$ 40 million.
  • Reduction of more than R$ 30 million in customs assessments involving special drawback arrangements.
  • Cancellation of assessment involving disallowance of ICMS credits in excess of R$ 9 million from a company in the metallurgical sector.

Court Litigation

We act strategically in the conduct of all types of lawsuits, from containment of complex liabilities to discussion of substantive and formal aspects of tax debts.

We use preventive controls, developed by our professionals, in order to protect the company’s bank accounts and assets in general and mitigate the risks of holding partners liable for the debts of the legal entity.

Our specialized work includes:

  • Representation of legal entities as plaintiffs and defendants aiming to cancel/reduce tax debts.
  • Use of customized management reports in Power BI format, mapping tax liabilities with possibilities of creating scenarios and projections.
  • Effective practice before all Brazilian Courts, including the STJ and STF.

In this context, our main achievements are:

  • Modification of decision involving attachment of financial assets in excess of R$ 28 million.
  • Exclusion of companies as defendants in a tax execution of more than R$ 45 million involving a discussion on the economic group.
  • Cancellation of ISS infraction notices of more than R$ 4 million.

Tax Review: Debt Collection

We practice in the judicial and administrative spheres with the objective of recovering unduly paid taxes and monetizing accumulated balances of tax credits, through:

  • Individualized mapping of tax credit recovery opportunities applicable to each business segment.
  • Filing of lawsuits with the purpose of recovering unduly paid taxes, at the federal, state, and municipal levels.
  • Advising companies in the administrative recovery of unduly paid taxes and in reimbursement of various types of tax credits such as PIS, COFINS, IPI, and REINTEGRA.

In this context, our main achievement is:

  • Recovery of more than R$ 100 million in unduly paid taxes for companies in various segments (2021/2022).

Equalization and Management of Complex Liabilities

Strategic management of tax liabilities with the purpose of questioning debt inconsistencies and formulating payment scenarios appropriate to the company’s cash flow, taking into account:

  • Detailed mapping of liabilities using BI tools.
  • Creation of payment scenarios aligned with the client’s financial outlook.
  • Representation before the tax authorities to negotiate debts via tax transactions, procedural legal business, and payment in kind.

In this context, our main achievements are:

  • Reduction of more than R$ 40 million – equivalent to 50% of the debt -, via a tax settlement of a company in the construction industry.
  • Equalization of tax debt with discounts for agribusiness companies, via tax settlement, with installment payments in 108 months and reduction of fines and interest.
  • Management of total liabilities in the firm of approximately R$ 3.2 billion using a Tax Dashboard.
  • Reduction of more than R$ 19 million in the reconfiguration of several special installment payment modalities for companies in the automotive sector.
  • Reduction of 3.6 million in the identification of errors by the National Treasury in the calculation of the special installment plan termination balance.

Cases de sucesso

O que dizem sobre nós

Our lawyers

Jayme Petra de Mello Neto

Foto Fábio Bernardo Advogado

Fábio Bernardo

Foto Tiago Silva Advogado

Tiago Aparecido da Silva

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