The firm
A personal, technical practice in São Paulo
FFernandes Advocacia advises companies, investors and families on Brazilian tax — in court and before it. Clients instruct from Brazil and from abroad, in English or in Portuguese.
How the work is done
A multidisciplinary reading of Brazilian tax
Doing business with Brazil — or holding assets, or defending a Brazilian tax file — requires a lawyer who can hold the statute, the invoice and the commercial fact in the same analysis. The firm was built for that demand: precise, consistent advice on federal and subnational tax, in court and before it, for companies and for individuals.
Dr. Fabio Fernandes trained as an engineer and as an accountant before qualifying as a lawyer, and later completed postgraduate work in tax law and business law. That background is the method: numbers, operational process and legislation are read together, with their patrimonial, criminal and group-level effects in view.
The practice covers tax strategy, controversy, credits, liability management, tax criminal matters, and wealth and succession — including the consumption-tax reform now underway. The aim is the same in every file: a clear decision, with the legal, accounting and personal effects in view.
Scope
Areas of work
Engagements are scoped to the matter. Each area below can be instructed in English.
Tax strategy
Structuring Brazilian operations and investments so the tax map, the commercial model and the group’s risk appetite stay aligned — including, where it matters, the consumption-tax reform.
Tax controversy
Defence in administrative and judicial tax proceedings, including assessments that a foreign group often first sees through a local controller or a Big Four memo.
Tax liability management
Review and restructuring of material Brazilian tax liabilities, with an eye on cash, contingency disclosure and what a foreign board can actually decide.
Tax credits
Identification, review and recovery of Brazilian tax credits — federal and, where the file supports it, state and excise — so a number in the group pack is the same number the ledger can defend.
Tax criminal matters
Counsel on criminal exposure that can attach to a Brazilian tax dispute, from the investigation stage through trial. Foreign parents and their outside counsel are instructed in English on what the file means and what the next filing is.
Wealth and succession
Tax structuring of personal and family assets with a Brazilian connection — for residents, for families with a Brazilian estate, and for investors whose succession question crosses the border.
Principles
What the mandate looks like
Brazilian tax work is not a recitation of the code. It is a judgement about legal, accounting and personal effects — and about what a client can safely put in a board paper or a family memo.
Technical range
Brazilian tax questions sit between statute, bookkeeping and operations. The work combines law, accounting and an engineering reading of process — so a structure, a credit, an assessment or a criminal file is examined as a whole, not as a citation.
Ethics and integrity
The file is the file. Advice states what the law supports, what remains political or unregulated, and what a foreign parent should not take on trust from a local spreadsheet or a second-hand summary.
Plain English
Foreign counsel, controllers and families need a map they can send upstairs. Risks, alternatives and the Brazilian clock are stated in the language of the mandate, not in a translation of a petition.
Preservation of value
Credits, liabilities, controversy and succession are cash and legacy questions. The practice is built to keep value in the group, the company operable, and the family’s assets in a structure that can be explained.
“Entrepreneurs and families take personal risk in a tax system that is still, for a foreign reader, unusually stacked and unusually documented. Each tax decision touches the company’s cash, the assets built over years and, in some files, the liberty of the people who signed them.
The work is therefore personal and technical. The statute is read against the invoice, the ledger and the contract — so that a holding company, a fund or a family outside Brazil can see the same facts the local file contains, in a language they already use.”
