Practice
Brazilian tax work, instructed in English
Strategy, controversy, credits, liabilities, tax criminal matters and succession — including the effects of the consumption-tax reform on operations, contracts and cash.
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.
- Corporate reorganisations with a Brazilian tax overlay
- Regime and entity mapping for inbound groups
- Tax due diligence on Brazilian targets and subsidiaries
- Preventive opinions for boards, funds and foreign counsel
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.
- Defence of tax assessments and infraction notices
- Administrative appeals and case monitoring
- Annulment and declaratory actions
- Tax writs of mandamus where the statute supports them
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.
- Review of federal and subnational tax liabilities
- Contingency and risk mapping for group reporting
- Strategies for high-value enforceable tax debts
- Monitoring of tax collections and related measures
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.
- PIS, Cofins, ICMS and IPI credit reviews
- Untimely credits, offsets and refunds
- Credits through the CBS and IBS transition
- Supplier-chain and invoice integrity where credit depends on it
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.
- Investigations and inquiries
- Defence in tax-related criminal actions
- Preventive measures and habeas corpus
- Release of seized goods where the facts support it
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.
- Succession planning with a Brazilian tax overlay
- Probate and partition
- Gifts and family holding structures
- Taxation of Brazilian investments and inheritances
Discuss a Brazilian tax matter
Write in English. The work is carried out under Brazilian law, from São Paulo.