Tax

Consulting

  • General tax assistance, including instructions and revision of tax filings, main and ancillary obligations
  • Analysis of tax disputes and compliance with accounting and tax aspects procedures
  • Analysis of impacts and opportunities of international transactions, including analysis of tax treaties
  • Price structure and tax implications
  • Tax impact in mergers, acquisitions and corporate reorganizations
  • Tax on shareholder/partner compensation: interest on equity vs. dividends
  • Analysis of sharing of costs and expenses in economic groups
  • Analysis and advice on general tax benefits, such as Special Customs Regimes, the Manaus Free Trade Zone, Regional Tax Incentives and the Brazilian Lei do Bem (investment in research and development)
  • Advice on tax jurisdictional conflicts and tax wars
  • Numerical analysis of tax impacts resulting from transfer price regulations, undercapitalization, Controlled Foreign Corporations – CFC and anti-fraud regulations
  • Analysis and advice on Customs taxes and duties. Analysis of controversies and measures for tax efficiency
  • Analysis of tax risks involved in all types of corporate transactions

Tax Planning

  • Analysis and advice on business models
  • Tax structuring of businesses and enterprises in Brazil and abroad, with emphasis on Latin America.
  • Mergers, acquisitions, consolidations, Spin-Offs and other corporate transactions
  • Filing of lawsuits for the reduction of taxes, increase of cash-flow and the refund of taxes (tax defenses)
  • Analysis and revision of procedures and recommendations to reduce tax exposure and increase fiscal efficiency
  • Numerical simulation of the tax burden of the different business models: trade, importing, manufacturing, services, etc.
  • Tax impacts for hiring and compensation of employees

Tax Litigation

  • Representation of clients in administrative tax procedures at the federal, state and local levels, both in the presentation of defense against notices of infraction and in discussions related to compensation and refund of taxes
  • Representation of clients in judicial lawsuits in both federal and state courts in the whole country, as well as in [higher/Supreme] courts
  • Active participation of administrative procedures and judicial lawsuits, including follow up and oral defense at hearings
  • Procedural advice for definition of strategies for defense and preventive measures according to each companies’ situation
  • Legal due diligences to identify tax liabilities and to evaluate their risks
  • Assistance in obtaining negative tax clearances (Certidões Negativas de Débito)
  • Assistance in implementing internal controls to optimize the monitoring of tax lawsuits and administrative procedures
  • Assistance in monitoring fiscal inspections