The area is dedicated to both consultancy and litigation, and comprises professionals with multidisciplinary training and experience serving companies in different sectors of the economy, thus enabling companies to face problems from a comprehensive perspective while remaining focused on the business.
Our consultancy services span municipal, state and federal taxes, including social security contributions, and encompassing mergers and acquisitions, the structuring of transactions, tax benefits, transfer pricing and due diligences, among others.
Our practice of judicial litigation comprises Ordinary Courts and Federal Courts, with a strong presence in Higher Courts. In administrative litigation, the team’s practice covers representation at all levels, including the Board of Tax Appeals (CARF) as well as state and municipal administrative courts.
Consultancy in the legislative process is also within the scope of the Tax area’s expertise. The team identifies the legislative measures to be submitted, drafts the proposals for legislative texts and defines the best strategy for their submission.
In addition, the team also focuses on Customs Law, both in consultancy and in judicial and administrative litigation, working with taxation on foreign trade transactions, tax classifications, special customs procedures, customs clearance of import and export goods, customs services and registrations with SISCOMEX and SISCOSERV.
Among the main activities developed by the area, the following activities stand out:
• Assistance in the sale and acquisition of control of corporations and business groups, involving negotiation and tax planning;
• Assistance to a petrochemical company in tax planning for the purchase of electricity in the context of free energy procurement;
• Representation of taxpayers in discussions about the ICMS levied on interstate transactions concerning electricity intended for use in industrial processes;
• Representation of a company in the food industry in discussions to define the ICMS tax base for interstate transfers that are subject to the tax substitution tax regime;
• Assistance to individuals and companies in tax planning regarding real estate operations;
• Assistance to companies in tax planning involving the purchase and sale of standing forests;
• Representation of a construction company in discussions related to ISSQN requirements regarding its activities and related to their respective basis for calculation;
• Assistance to and representation of individuals and legal entities in discussions regarding tax liability in successions triggered by corporate changes;
• Assistance in the sale of real properties and in setting up a joint venture for the exploration of industrial warehouses and logistics areas;
• Assistance in the structuring of an international transaction for the purchase of creditor rights, aiming to reduce tax impacts;
• Development of tax planning for a group of companies in the renewable energy sector;
• Assistance to companies aiming to identify and recover tax credits, including social security contributions;
• Assistance to companies aiming to meet accessory obligations, including SPED and eSocial systems;
• Assistance to and representation of companies in discussions related to FAP;
• Representation of electronics corporations in their defenses against tax assessments issued by the Brazilian Federal Revenue regarding the tax classification of goods imported into Brazil;
• Assistance to a company in the shipbuilding and Offshore sector regarding the tax treatment to be granted to transactions involving industrialization by order within the Special Customs Warehouse Regime;
• Representation of companies before the IRS and the Attorney General of the National Treasury for the reduction and cancellation of debts in administrative review procedures;
• Representation of a consortium made up of construction and equipment supply companies in an arbitration involving the allocation of tax burdens;
• Representation of companies in lawsuits challenging the collection of the Administrative Services Fee – Taxa de Serviços Administrativos – TSA (SUFRAMA).