Souto Correa’s Tax team is expert in both consulting and litigation with multidisciplinary experience and works with municipal, state, and federal taxes, including social security contributions. Our professionals in this area provide services to companies in many different economic sectors, always striving to improve their knowledge of each client’s sector. This way, they can work together to find the best alternatives and opportunities.

The practice area’s consulting services encompass international and local tax planning, mergers and acquisitions, transfer pricing, profit-sharing plans, discussions of tax premiums; support in due diligence, structuring and negotiation of transactions, securing and assisting in negotiations regarding tax benefits, and participation in drafting legislation. Our litigation practice covers all instances, including state and federal courts, and is also very active in the Superior Courts. In administrative litigation, our team also practices at all levels, including the Administrative Council of Tax Appeals (CARF) and state and municipal Administrative Courts.

Moreover, our Tax team has solid practice in Customs Law and taxation in foreign trade operations, tax categorization of goods, special customs regimes, customs clearance of goods in imports and exports, customs clearance, and consultancy for SISCOMEX registrations.

Our clients describe our Tax practice as “a very experienced, senior team that has broad knowledge of tax law, including direct and indirect taxes, and also develops close relationships with its clients,” and that “the lawyers on the team are business-oriented, always willing, and have impeccable legal skills.” When commenting on the area’s most senior partner, clients say that “Henry Lummertz is an expert in constitutional tax law and customs matters,” with ‘a broad background in tax litigation and experience in handling high-profile cases before the Supreme Court,’ being ‘extremely capable in many areas of tax law, covering direct and indirect taxes,’ and highlighting his ‘impeccable technique, mindset, and willingness’ (Chambers and Partners).

Recent representations

  • Tax consultancy for cryptoactive exchange in several business areas, as well as in cashback business models and tax consultancy in fintech structuring.
  • Consultancy to leading companies in the technology, petrochemical, health, and energy markets, including IRPJ, ICMS, ISSQN, Social Contributions (CSLL, PIS, COFINS and INSS), Tax Benefits, Customs and Regulatory Controls.
  • Legal counseling to a leading group in the Latin American chemical and petrochemical sector in structuring operations for the import of natural gas (NG) and liquefied natural gas (LNG), focusing on the impacts and reduction of tax risks involving ICMS, PIS, COFINS, IRPJ, and CSLL.
  • Acting in the capacity of amicus curiae, representing a business confederation in the Direct Unconstitutionality Action No. 7. 066, filed by ABIMAQ for the purpose of securing interpretation of article 3 of Supplementary Law No. 190/2022 (DIFAL/ICMS). This is to the effect that such a law must respect not only the nonagesimal precedence, provided for in item “c” of section III of the main section of article 150 of the Brazilian Federal Constitution, but also the annual precedence, provided for in item “b” of section III of the main section of article 150 of the Federal Constitution.
  • Legal counseling to wind and solar energy generation companies, particularly in reviewing the implementation structure of parks and defending against collection of ISSQN and municipal taxes.
  • Strategic planning and counseling in securing special regimes at municipal and state levels for technology, e-commerce, and marketplace companies, as well as counseling in consolidating CONFAZ regulations on tax processing related to ICMS (Value-Added Tax on Sales and Services) for operations related to electric power in the Free Energy Market.
  • Consultancy in structuring operations in the free energy market, aiming at risk assessment and tax implications in new business models.
  • Consultancy and representation at administrative and court levels of companies from varied economic sectors regarding their eligibility for ICMS credit in the acquisition of goods (inputs and fixed assets) considered essential for the performance of the activities that constitute the corporate purpose of the respective business establishments.
  • Negotiation of individual tax transactions with the Attorney General of the National Treasury, with a view to the application of discounts, payment in progressive installments, deferral of payment, and use of tax losses, as well as counseling in the compliance with other types of transactions.
  • Legal counseling in matters related to international taxation covering receipts and payments to foreign sources; international corporate reorganizations; and taxation of profits of foreign subsidiaries and affiliates.
  • Legal counseling in drafting and reviewing short- and medium-term incentive plans and compensation of executives of companies in a number of industries.


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