Latin America

Brazil

Tax


Brazil : AN INTRODUCTION

Contributed by Lefosse Advogados

Brazil is a federative state, similar to the US, but with three constitutional levels of public administration, namely (i) municipalities (ii) member states and (iii) union. Brazil’s ”new” Federal Constitution of 1988 is very detailed and in many aspects quite specific. In particular, all competences to impose taxes on Brazilian taxpayers are divided among the three federal levels while at the same time the Brazilian Constitution allocates duties and tasks to be performed by each of the three administrative levels (thereby triggering heavy financial obligations/costs at each of these three admin levels). As a result, each of the tax administrations of the three administrative levels issue tax laws and collect taxes which are sometimes conflicting while the tax administrations are also eager to collect taxes.

Very little has been done in 2014 to reduce the high complexity of the Brazilian tax system. This complexity has historically been driven by a combination of factors, the main being (i) the aforementioned different layers of taxing jurisdiction (i.e., federal, state and municipal), (ii) the intensive legislative activity, (iii) the significant time that is sometimes taken for a view on the interpretation of tax legislation to be officially expressed by the tax authorities, and (iv) the often aggressive positions of the tax administration, with “dialogue channels” not well established with the business community.

Notwithstanding, the first half of 2014 has seen the issuance of a new law on two tax matters about which regulation has been long-awaited by the business community: (a) a detailed and definitive regulation on the tax implications of the new Brazilian accounting rules (which are very similar to IFRS and came into force in 2008) and (b) taxation of the profits of foreign subsidiaries.

With regards to matter (a) above, although it will probably end up increasing the already high Brazilian tax burden, the new law is expected to create more stability and certainty to taxpayers as it not only abolished the need to take into consideration different accounting methods and criteria for purposes of calculating taxable income vis-à-vis those applicable for accounting purposes (IFRS), but also clarified, even if in some cases only partially, certain controversial issues. Those issues include, among others, the application of income tax exemption for dividends paid based on accounting profits that exceeded the profits subject to corporate income taxation, a clear definition of the cases in which a certain investment must be evaluated for tax purposes according to the equity method and a new regime for the calculation and use of goodwill for tax purposes that is more aligned with IFRS.

In relation to matter (b) above, the new law frustrated the expectations of the business community, especially Brazilian multinationals, which unsuccessfully tried to convince the government and legislators to substantially change a taxation regime of foreign subsidiaries that is unprecedented in other developing and developed countries, i.e. a regime where the income of foreign subsidiaries has basically to be fully taxed in Brazil at the end of each year even if no dividends are distributed and regardless of: (i) whether those subsidiaries are domiciled in low-tax jurisdictions or subject to a privileged tax regime or not, (ii) whether those subsidiaries have business substance or have been created with the only purpose of saving taxes, and (iii) whether the income earned by those subsidiaries is active or passive (e.g. income arising from interest, royalties and dividends). Indeed, despite certain innovations such as the possibility of partially deferring payment of the income taxes due on profits of foreign subsidiaries, as well as a presumed tax credit for the beverage, food, civil construction and infrastructure sectors, the design of the new law does not solve most of the issues and complexities of the previous one.

As a result of the reduction of tax collection because of the slowing down of economic activity in 2014, both federal and state governments recently created or extended certain tax amnesty programs as a way to stimulate taxpayers to collect overdue taxes.

On the other hand, the government continues to use the tax system as a way to encourage (or discourage) behaviour by economic agents. An example was the recently created income tax exemption for capital gains earned by Brazilian individuals in the sale at the stock exchange of small cap companies that comply with certain requirements. The declared aim of this exemption is to foster the growth and development of the Brazilian capital markets by incentivising both the listing of smaller companies and investments by Brazilian individuals.

On a different front, the Internal Revenue Service (IRS) is becoming better equipped for auditing activity each year, being able to cross-check information electronically provided by taxpayers in a wide range of different tax returns. Centralised co-ordination of audits and the creation of specialised audit teams for specific issues enabled the IRS to issue several tax assessments in 2014 with values exceeding BRL1 billion.

In addition to targeting tax evasion and general non-tax compliance, the IRS has been focusing its efforts on challenging tax planning structures that, according to its internal policies, are considered abusive - despite in several cases being arguably allowed by tax law.

While this concentrated effort by the IRS emphasises, on the one hand, the need for time and consideration to be spent in properly structuring deals and documenting one’s position, it indicates, on the other hand, that tax litigation will continue to be a constant theme for multinationals operating in Brazil or for large Brazilian corporates in their domestic and international affairs.

Tax - Brazil

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第一等 |

Basic facts about the department - 2 qualified lawyers

What the team is known for Highly respected boutique practice with many years of experience in the tax sphere. Particularly well known for advising high-profile domestic clients in complex judicial and administrative litigation processes, and also advises on a broad range of other tax-related issues.

Strengths (Quotes mainly from clients)

"Advocacia Krakowiak is the highlight of all the firms we have worked with. It is a point of reference in the field."

Notable practitioners  

Sources comment that Leo Krakowiak is "extremely accomplished." He has a wealth of experience and is well regarded by peers and clients alike for his market-leading litigation skills.

Ricardo Krakowiak is a well-respected figure in the tax arena and a renowned litigator. He is praised by clients for the excellent quality of his work.

第一等 |

Basic facts about the department - 11 partners
 - 68 other qualified lawyers

What the team is known for Large practice with capabilities in the full spectrum of tax matters. Particularly involved in transactional work for domestic and international clients, including issues of foreign investment, private equity and corporate restructurings. The experienced team has strength in both direct and indirect tax.

Strengths (Quotes mainly from clients)

"The firm deploys its cross-functional expertise whenever needed, and its lawyers have very strong knowledge of the tax market."

Work highlights Advised EIG Global Energy Partners on structuring, negotiating and drafting all necessary agreements for a BRL1.3 billion deal to control LLX.

Notable practitioners  

Celso Costa is a respected figure in the field. He has been particularly active in the past year in import tax and M&A deals.

Sources comment that Raquel Novais is a "standout name" at the firm due to the quality of her work.

Marco Antonio Behrndt is commended by clients for his "huge experience in complex tax procedures." He is especially well known for his work in litigation.

Daniella Zagari Gonçalves has experience in a number of fields within the tax arena and is a key member of the firm's tax practice.

Clients are full of praise for Fernando Tonanni: "He is always available and gives us the feeling that he is a real team player and an asset to our company." 

Marcelo Paulo Fortes de Cerqueira is recommended by clients for his knowledge of tax litigation issues, and for his in-court experience.

第一等 |

Basic facts about the department - 8 qualified lawyers

What the team is known for Well-reputed boutique practice with an extensive track record and highly prized for the quality of its legal opinions. Expertise lies in indirect taxation, social security, corporate contracts and administrative litigation processes. The team can count on the leadership of one of the most prominent practitioners in the field.

Strengths (Quotes mainly from clients)

"A point of reference in the market; a real standout firm." 

Notable practitioners  

Founding partner Ricardo Mariz de Oliveira is praised by market commentators as "one of the best tax lawyers in Brazil."

João Francisco Bianco is the firm's managing partner. He is a recognised figure with diverse strengths within the tax sector.

Key partner Roberto de Siqueira Campos is particularly well known for his litigation capabilities.  

第一等 |

Basic facts about the department - 14 partners
 - 53 other qualified lawyers

What the team is known for Leading practice with a large group of lawyers and strength in many areas of tax law, especially in matters relating to VAT, litigation and entity taxation. Active with clients from a range of industries, including pharmaceuticals, energy and banking and finance. Offices in São Paulo, Rio de Janeiro and Brasília.

Strengths (Quotes mainly from clients)

"It provides excellent quality work and has a good reputation with the authorities. We go to them when we have complex cases."

What's new? The team promoted two associates to partners.

Work highlights Acted as counsel to Socopa in successful litigation against the federal government, which had alleged that the company had distributed disguised profits and therefore underpaid its corporate tax. The matter was worth BRL600 million.

Notable practitioners  

Sources reserve high praise for Roberto Quiroga Mosquera: "He is excellent - one of the most important lawyers in Brazil for tax matters." He is equally well versed in consultancy and litigation matters. 

Clients are quick to recommend Andréa Bazzo Lauletta for her expertise in the tax arena. She is noted for the depth of her technical knowledge.  

Luiz Felipe Centeno Ferraz has been especially active over the past year on tax issues within corporate transactions, working closely with other departments at the firm.

According to clients, Glaucia Maria Lauletta Frascino is "very driven and enthusiastic, and our go-to lawyer for complex litigation matters and tax planning." 

João Marcos Colussi is a key player in the team. He regularly represents clients in front of administrative and judicial courts.

Maria Isabel Tostes da Costa Bueno has notable expertise in handling complex cross-border mandates. She has over 20 years of experience in tax law.

Founding partner Pedro Luciano Marrey Jr is a highly respected market figure with decades of experience.  

Renata Correia Cubas is highlighted by peers for her in-court skills.

Significant clients Arcos Dourados (McDonalds), Embraer, White Martins Gases Industriais, Banco Santander, Citibank.

第一等 |

Basic facts about the department - 15 partners
 - 74 other qualified lawyers

What the team is known for Full-service firm with a large, well-respected tax practice that advises on the full range of consultancy and litigation matters. Often works in tandem with the firm's leading corporate and contentious teams to provide well-rounded advice. Extensive experience in cross-border deals attracts international and multinational companies looking for high-quality local support.

Strengths (Quotes mainly from clients)

"I would recommend Pinheiro Neto for its high-quality work and success rate."

What's new? Jorge Lopes Jr, Flávio Veitzman and Ana Luisa Varella were made partner. 

Work highlights Acted as counsel to Columbian Chemicals Brasil in a successful appeal against a series of fines and infraction notices issued by the Brazilian federal tax authorities, worth a total of BRL64 million.

Notable practitioners  

Luciana Rosanova Galhardo is well respected within the field, and particularly highly regarded for the strength of her administrative and judicial litigation work.

Ricardo Becker specialises in structuring deals for clients from the banking and finance sector, and is able to call upon the support of the firm's strong transactional experts when handling complex mandates.

Clients praise Luiz Roberto Peroba Barbosa for his "high level of legal expertise" within the tax sector, especially in litigation.  

Giancarlo Chamma Matarazzo is commended by clients for his "impeccable commitment and knowledge of the subject."

Key partner Tércio Chiavassa has experience in leading the team in tax deals and specialises in litigation and domestic tax law.

第一等 |

Basic facts about the department - 21 partners
 - 22 other qualified lawyers

What the team is known for Leading tax boutique based in Belo Horizonte. Extensively experienced in a broad range of tax matters, including planning, indirect tax, risk analysis and, above all, litigation. Includes some of the country's leading tax experts and is often sought for sophisticated legal opinions. Clients include high-profile domestic and international corporations.  

Strengths (Quotes mainly from clients) 

"An outstanding practice and a point of reference in the sector. We appreciate the fact that they can assign a special team for us, making the work very smooth."

Notable practitioners  

Name partner Misabel Abreu Machado Derzi is particularly well known for her legal opinions and contentious experience. She formerly worked in high-level government office.

Clients are quick to praise name partner Sacha Calmon Navarro Coelho, stating: "He is a specialist who handles complex matters well and offers good client service." He has been practising law for almost 50 years and is also respected for his academic work.

Igor Mauler Santiago focuses his practice mainly on litigation within the tax arena. He works from the firm's São Paulo office.

Eduardo Maneira also has notable strength in corporate law and therefore often works in deals that have transactional elements.

André Mendes Moreira is lauded by clients for his "creativity and expertise."

Sources single out Valter de Souza Lobato for his command of tax litigation issues.

第一等 |

Basic facts about the department - 12 partners
 - 45 other qualified lawyers

What the team is known for Large team of experts at this highly regarded Rio de Janeiro firm, with a wealth of experience in domestic and international tax law. Adept in both litigation and planning, in addition to matters related to transactions, such as restructurings and acquisitions. Often works alongside the firm's corporate and regulatory teams, and its caseload spans the whole country.

Strengths (Quotes mainly from clients)

"We have been very impressed with the team as they provide high-quality services across the board: the technical quality of the work is excellent, the lawyers are proactive and deadlines are kept."

What's new? Mariana Jatahy was made partner. 

Notable practitioners  

Gustavo Brigagão leads the team in many of its most important deals. He focuses on tax consultation and administration.

Key partner Luiz Felipe Carvalho has expertise in direct tax, specifically consultation and administrative litigation.  

Judicial litigation is one of Antonio Carlos Garcia de Souza's strongest suits; he has additional experience in tax consultation.  

Sources recommend Rodrigo Brunelli Machado for his dedication and diligent approach.

Founding partner João Dodsworth Cordeiro Guerra has vast experience in the field of corporate tax and is highly regarded by peers and clients alike.

Fellow founding partner Carlos Alberto Ulhôa Canto is lauded by clients for his "unbeatable technical knowledge." He specialises in corporate tax law.

Significant clients FIFA, Credit Suisse, BTG Pactual, MATCH Hospitality.

Band 2 | Dias de Souza

第二等 |

Basic facts about the department - 20 qualified lawyers

What the team is known for Long-standing tax boutique focusing primarily on administrative and judicial litigation. Notable experience in advising domestic and international clients from the financial, telecommunications and automotive industries.

Strengths (Quotes mainly from clients)

"Stands apart for its solid technical knowledge allied to vast procedural experience and good rapport with the authorities. I would also highlight their responsiveness and interpersonal skills."

Notable practitioners  

Name partner and eminent tax litigator Hamilton Dias de Souza has over 50 years of experience and is widely regarded as one of the leading practitioners in the field.

Clients say Mário Luiz Oliveira da Costa "is always available and goes out of his way to assist our every need."

第二等 |

Basic facts about the department - 6 partners
 - 26 other qualified lawyers

What the team is known for Celebrated tax department at an established commercial firm, with one of Brazil's top tax lawyers and foremost experts on transfer pricing matters. Regularly advises high-profile international clients from its offices in São Paulo, Rio de Janeiro and Brasília.

Strengths (Quotes mainly from clients)

"They are focused and efficient, and we can count on them for our most complex matters."

Work highlights The team has acted as counsel to a number of domestic companies in their defence against tax claims by the federal government.

Notable practitioners  

Luís Eduardo Schoueri is praised by sources as "a pioneer" and remains one of the most sought-after lawyers for tax legal opinions. He is an authority on transfer pricing issues and also advises clients on corporate-related tax matters.

第二等 |

Basic facts about the department - 4 partners
 - 15 other qualified lawyers

What the team is known for Highly regarded São Paulo firm with an impressive reputation in the field of tax. Regularly advises significant clients on a range of transactional matters, especially in M&A, capital market and banking deals. Also experienced in cross-border operations and contentious matters.

Strengths (Quotes mainly from clients)

"The partners have great knowledge in their field of work. Lefosse is a dynamic, focused and business-oriented law firm."

Work highlights Acted as counsel to Ambev on all tax issues relating to a BRL90 billion stock swap merger transaction.

Notable practitioners  

Clients describe head of department Gustavo Lian Haddad as "a first-class specialist." Others add that he "is extremely responsive and has broad experience of complex tax matters."

Ricardo Bolan has notable experience in international tax planning and consultancy. He is a key member of the team and regularly acts as lead partner in high-level deals.

Significant clients Cummins, Anheuser-Busch InBev, Ingram Micro, Syngenta, Microsoft.

第二等 |

Basic facts about the department - 13 partners
 - 51 other qualified lawyers

What the team is known for Large and capable practice with notable strength in tax matters related to the corporate sphere, such as international tax planning, M&A and transfer pricing. Clients also praise the firm's well-rounded litigation group.

Strengths (Quotes mainly from clients)

"The team is committed to deadlines and the association with Baker & McKenzie provides us with prompt advice from highly qualified experts all over the world."

Notable practitioners  

Sources comment that Simone Dias Musa is "always available and willing to understand the client's problems and needs." Others add: "She knows how to balance pure technical expertise with business applicability."

Key partner Paulo Sehn is head of the practice's litigation division and is a well-known figure in the market.

Clients say Clarissa Giannetti Machado is "very experienced in local tax law." Her expertise spans litigation and fiscal planning.

Maria Fernanda Furtado Fernandes is highly recommended by clients: "Her advice has been outstanding and very thorough, and will support our business plans in Brazil for the next few years." She stands out for her vast experience in tax issues for the offshore industry. 

Significant clients Citibank, Monsanto.

第二等 |

Basic facts about the department - 9 partners
 - 39 other qualified lawyers

What the team is known for Active group with strength in a variety of areas within the tax sphere, including planning, private equity, litigation and customs and trade. Represents a stellar portfolio of international companies and high-profile domestic players from a variety of sectors, including oil and gas, mining, power and telecoms.

Strengths (Quotes mainly from clients)

"The practice's tax advice is phenomenal. The lawyers are knowledgeable and able to provide simple solutions for complex issues."

Work highlights Acted as counsel to Philip Morris in a number of tax litigation cases, including one relating to the non-payment of excise tax on goods misappropriated in transit.

Notable practitioners  

Senior partner Ian Muniz has expertise across many areas of tax, particularly in issues related to M&A and customs. Clients say: "He is extremely responsive and has a great deal of knowledge and experience."

Abel Amaro is "one of the most well-respected tax lawyers in Brazil," say clients, adding: "His experience enables him to add extremely valuable input during discussions."

João Agripino Maia is a tax specialist with particular expertise in mergers, acquisitions and excise duties.

Clients reserve high praise for Márcio Calvet Neves, with one commenting: "He is very knowledgeable and extremely proactive. We really enjoy working with him."

André de Souza Carvalho is praised by clients for his ability to handle complex tax matters, especially planning issues.

Silvania Tognetti specialises in tax planning and litigation proceedings.

Significant clients Philip Morris International, Nokia, Universal Music, BT, Volvo.

第二等 |

Basic facts about the department - 3 qualified lawyers

What the team is known for Tax boutique with a compact but much-admired group of experienced lawyers. Acts as counsel to clients in complex international taxation matters and advises on litigation and consultancy procedures. Formerly a part of Xavier Bragança Advogados, and now has offices in São Paulo, Brasília and Rio de Janeiro.

Strengths (Quotes mainly from clients)

"The firm is excellent and a point of reference in the market for tax income issues." 

Notable practitioners  

Alberto Xavier is described by market commentators as "a star in this field" and "an authority on international tax matters."

Clients are quick to highlight Roberto Duque Estrada's balanced and measured approach to his work.  

Renata Emery is an experienced tax lawyer and a valuable team member.

第三等 |

Basic facts about the department - 5 partners
 - 27 other qualified lawyers

What the team is known for Well-established group with a standout reputation for corporate-related tax matters. Restructuring, planning and devising tax regimes have traditionally been the firm's primary focus but the practice is now recognised for its broader fiscal capabilities, including in litigation and sophisticated tax consultancy.

Strengths (Quotes mainly from clients)

"The team is made up of experienced and business-oriented lawyers who display excellent technical skills."

Work highlights Retained by General Atlantic to advise on tax-efficient structures in the company's BRL400 million acquisition of 16% of shares issued by Smiles Participações.

Notable practitioners  

Paulo Marcelo Bento heads the practice and is well regarded by market sources for the quality of his work.

Key partner José Otavio Faloppa's expertise lies in corporate matters related to tax, especially restructuring processes.

Significant clients Infoglobo, Johnson Controls, White Martins, Comgás.

第三等 |

Basic facts about the department - 4 partners
 - 55 other qualified lawyers

What the team is known for The core practice at this mid-sized Rio de Janeiro firm is particularly well known for its strength in administrative and judicial tax litigation, and is able to provide further support in corporate and commercial tax planning. Handles complex mandates, in addition to providing daily support and dealing with large-scale claims. Regularly retained by high-profile domestic players. 

Strengths (Quotes mainly from clients)

"The team's key strengths are flexibility, availability, responsiveness and expertise in litigation."

Work highlights Acted as counsel to Brascan Químicos e Soldas (Brookfield Incorporações) in its successful defence against USD8 million tax and regulatory fines issued by the Inland Revenue authorities.

Notable practitioners  

Clients say Luiz Gustavo Bichara "has built an excellent relationship with our company. We really appreciate the quality of the work he delivers and the fact that he is always available." 

Significant clients AmBev, Organizações Globo, Morgan Stanley, Sociedade Michelin de Participações Indústria e Comércio, Lafarge.

第三等 |

Basic facts about the department - 5 partners
 - 18 other qualified lawyers

What the team is known for Solid tax practice with consultancy and litigation capabilities. Regularly advises on issues related to the real estate industry, working closely with the firm's corporate department to offer clients a fully integrated service. Attracting an increasingly international clientele with the help of associated firm DLA Piper.

Strengths (Quotes mainly from clients)

"The firm has talented lawyers and is able to handle cases in a practical and creative way."

Notable practitioners  

Guido Vinci is lauded by clients for his "experience and problem-solving skills." His workload includes corporate tax planning and contentious matters.

Significant clients Sony, Crocs, Prada, TIM Participações, MasterFoods.

第三等 |

Basic facts about the department - 18 partners
 - 27 other qualified lawyers

What the team is known for Full-service firm fielding a large and multidisciplinary team of tax partners. Often works in tandem with specialists from other areas, namely corporate, real estate, international trade and disputes. Equipped to advise national and international clients on transactional, regulatory and contentious tax matters.

Strengths (Quotes mainly from clients)

"It is a large firm that offers a personalised service and delivers high-quality work."

Work highlights Advised Fibria Celulose on the tax aspects of its USD693 million land sale to agribusiness investment group Parkia Participações, while retaining the right to own 60% of raw material output.

Notable practitioners  

Sources say Catarina Rosa Rodrigues is "extremely committed and knowledgeable of the legislation," and add: "She always seeks the most complete solution possible." 

Department head Oswaldo Leite de Moraes Filho has notable strength in matters related to customs, and handles both consultancy and litigation matters.

Eloisa de Almeida Rego Barros Curi is praised by clients for her solution-oriented approach. She has particular expertise in cross-border mandates.

Significant clients Petroleum Geo-Services, Goodyear, Volkswagen, Jaguar Land Rover, Diebold.

第三等 |

Basic facts about the department - 13 partners
 - 37 other qualified lawyers

What the team is known for Houses an extensive team of tax experts who are routinely praised for their technical knowledge and accountancy background. Advises a portfolio of international clients on the full spectrum of contentious and non-contentious tax matters. Especially well regarded for its expertise in transfer pricing, import/export taxes and litigation, as well as daily support.

Strengths (Quotes mainly from clients)

"They stand out for their communication skills, well-rounded experience of the law and high-quality team."

Work highlights Advised Natura Cosméticos in its tax litigation proceedings against claims that the company had underpaid its tax bill by around USD683 million.

Notable practitioners  

Julio de Oliveira is recognised by sources for the depth of his experience in the field. His workload spans VAT and litigation matters.

Luís Rogério Farinelli specialises in a range of corporate-related tax matters, such as M&A, restructuring and international investment.

Founding partner José Maurício Machado specialises in M&A-related tax matters and is well regarded by sources for his experience in corporate reorganisations.

Significant clients Natura Cosméticos, Andrade Gutierrez, SC Johnson, Colgate-Palmolive, C&A.

第三等 |

Basic facts about the department - 10 partners
 - 78 other qualified lawyers

What the team is known for One of the largest tax practices in Brazil and a respected player in the market. Split into two sub-departments – litigation and consultancy – that cover a wide range of tax issues, including review and implementation of tax structures, corporate tax planning, and administrative and judicial litigation. Based in Belo Horizonte with additional offices in Rio, São Paulo, Curitiba and Brasília.

Strengths (Quotes mainly from clients)

"I work with the firm for the quality of service, knowledge of the client's business and personal attention."

Notable practitioners  

Clients are quick to single out head of department João Dácio Rolim for his personable and approachable style. He is also considerably involved in academic matters.

Cristiano Augusto Ganz Viotti is highlighted by clients for his "availability, technical skill and knowledge of our business." He focuses on tax planning and VAT.

Significant clients Fiat, Shell, Companhia Energética de Minas Gerais, Heineken.

第三等 |

Basic facts about the department - 4 partners
 - 30 other qualified lawyers

What the team is known for Regularly works alongside the firm's celebrated corporate and finance departments to advise clients on matters arising from M&A, reorganisations, project financing, capital markets transactions and joint ventures. Also equipped to handle the contentious side of tax, including judicial and administrative proceedings.

Strengths (Quotes mainly from clients)

"The firm's commitment to clients and its profound knowledge of the law are its key assets. Their lawyers are proactive and understand the business context in which negotiations take place."

What's new Ramon Machado Castilho was made partner.

Work highlights Providing full assistance to Portugal Telecom in its merger with Oi, including advising on implementing tax-efficient measures that are expected to save the newly established entity some BRL1.4 billion over the next five years.

Notable practitioners  

Founding partner and head of department Roberto Barrieu is commended by clients for his "commitment and depth of knowledge." He has extensive experience in working on multi-jurisdictional transactions and is also recognised for his accountancy expertise.

Clients say Ramon Machado Castilho "always seeks efficient solutions that make sense from a business standpoint." He focuses primarily on providing tax advice for corporate deals. 

Significant clients Brookfield Asset Management, Grupo Pão de Açúcar, Hypermarcas, Abengoa Bioenergía.

第三等 |

Basic facts about the department - 9 partners
 - 22 other qualified lawyers

What the team is known for Well-regarded practice acting as counsel to clients from many industries and focusing on tax aspects of significant corporate transactions. Particularly noted for its work on restructuring and foreign investments, and also active in litigation proceedings.

Strengths (Quotes mainly from clients)

"I would highlight the firm's expertise, deep knowledge and strategic approach to complex transactions as its main strengths."

Work highlights Advised Coca-Cola FEMSA on all tax matters related to two acquisitions of local bottling companies, worth a combined total of USD2.3 billion.

Notable practitioners  

Head of department Ana Cláudia Utumi is highly regarded by sources, who describe her as "one of the best tax lawyers in Brazil." She specialises in tax for transactional mandates.

Significant clients DHL, BMW, Toshiba, Samsung, McCain Foods.

第四等 |

Basic facts about the department - 2 partners
 - 13 other qualified lawyers

What the team is known for The solid tax practice at this long-standing commercial firm assists prominent domestic and international clients with the full range of fiscal matters, including corporate tax, tax credits, transfer pricing issues and litigation.

Strengths (Quotes mainly from clients)

"We work with them a lot and their advice has saved us millions. They are exceedingly prompt and always available when we need them."

Work highlights Advising White Martins Gases Industriais (Praxair) on developing its strategy for filing, negotiating and obtaining special tax regime status across several states in Brazil.

Notable practitioners  

Clients are full of praise for head of department André Gomes de Oliveira: "He is technically impeccable and approaches issues from not just a legal but also a business standpoint, enabling us to make important decisions with confidence."

Significant clients TIM, Grupo Espírito Santo, Medidata Informática, IRB Brasil Resseguros, Orange Business Services.

第四等 |

Basic facts about the department - 1 partner
 - 4 other qualified lawyers

What the team is known for Compact tax group well regarded by the market for its ability to advise on tax planning, tax credits and VAT. Clients also highlight the practice's ability to handle complex international mandates, especially in matters related to corporate transactions.

Strengths (Quotes mainly from clients)

"This is a committed and highly experienced team of talented lawyers, offering clients a personal approach and rapid rate of response."

Notable practitioners  

Department head Antonio Amendola is commended by clients for his expertise in tax and his creative approach to complex mandates. He has notable experience in tax matters that have a significant cross-border aspect.

第四等 |

Basic facts about the department - 41 qualified lawyers

What the team is known for Experienced group, especially active with clients from the corporate sector. Praised for its strength in administrative matters, tax planning and litigation proceedings. Office network covers São Paulo, Rio de Janeiro, Curitiba, Belo Horizonte and Brasilia.

Strengths (Quotes mainly from clients)

"A specialised firm that stands out in compliance and administrative mandates."

Notable practitioners 

Founding partner Fernando Antonio Cavanha Gaia is the key client contact.

第四等 |

Basic facts about the department - 3 partners
 - 13 other qualified lawyers

What the team is known for Medium-sized firm with an established tax practice that advises domestic and international clients on a broad range of fiscal matters. Particularly active in issues arising out of corporate transactions, including restructurings, joint ventures and M&A. Also offers day-to-day counsel to clients.

Strengths (Quotes mainly from clients)

"I would highlight the firm's responsiveness and proficiency in every subject matter. The lawyers understand a US business approach and their support is of a very high level."

Work highlights Providing full assistance to shipbuilder Ecovix-Engevix in the structuring of a USD305 million M&A deal with a Japanese consortium, including advising on tax assessment and income tax issues.

Notable practitioners  

Head of department Henrique Lopes is highlighted by clients for his expertise in the tax arena.

Key partner Victor Polizelli is praised by sources for his intellectual acuity and strong academic background.

Significant clients General Mills, WPP, Freudenberg, Newell Rubbermaid, Hamburg Süd.

第四等 |

Basic facts about the department - 4 partners
 - 6 other qualified lawyers

What the team is known for Particularly noted for its expertise in assisting clients from the banking and finance sector. Also able to count on the support of the firm's corporate and litigation departments when dealing with issues such as tax structuring, transfer pricing, fiscal incentives and tax assessment disputes.

Strengths (Quotes mainly from clients)

"Excellent technical and practical skills, and experience in dealing with complex matters."

Work highlights Advised Refinaria de Petróleo Riograndense on a legal challenge against interest received on equity being included in its tax report.

Notable practitioners  

Vinicius Branco is commended by clients for the depth of his experience in tax matters related to banking and finance. He is also recognised by sources for his work in personal income tax and litigation.

Isabela Schenberg Frascino has notable strength in a number of areas within the corporate tax arena, particularly tax planning and private equity issues.

Key partner and joint head of department Ana Carolina Monguilod focuses on local tax planning for major financial institutions.  

Significant clients Unilever, Citibank, Lufthansa AirPlus, Barclays, Santander.

第四等 |

Basic facts about the department - 3 partners
 - 7 other qualified lawyers

What the team is known for Consultancy and litigation are core areas for the tax group at this well-regarded firm. The team regularly works alongside other departments at the firm, most notably corporate, real estate and infrastructure, to provide clients with comprehensive assistance.  

Strengths (Quotes mainly from clients)

"The firm offers a cost-effective service and has some of the best technical lawyers in the market."

Notable practitioners  

Key partner Alexandre Siciliano Borges focuses his practice on international tax, tax planning and transfer pricing.

第四等 |

Basic facts about the department - 7 partners
 - 61 other qualified lawyers

What the team is known for Large practice with strength in litigation, consultancy, social security and tax burden reduction. Able to draw on its 19 regional offices to provide close client service across the country.

Strengths (Quotes mainly from clients)

"An expert legal body that is characterised by its quick responses, understanding of our business needs and availability." 

Work highlights Acted as counsel to Banif Financial Group in a number of tax deals, including social security, income tax and litigation, worth a combined total of USD90 million.

Notable practitioners  

Market commentators say Richard Edward Dotoli is "committed, responsible and able to offer intelligent and appropriate solutions."

As well as a strong litigation practice, Maucir Fregonesi Jr also has expertise in international tax planning. Clients comment that his "great agility and objectivity" are assets to their business.

Significant clients Nextel Telecomunicações, Samsung, Kellogg, Peugeot, Sony.

第四等 |

Basic facts about the department - 3 partners
 - 15 other qualified lawyers

What the team is known for Particularly well known for its depth of experience with clients from the oil and gas industries. Also has notable strength in international taxation, and can call upon the support of a network of global offices when handling complex cross-border mandates.

Strengths (Quotes mainly from clients)

"The lawyers are responsive and offer a high level of technical expertise. Furthermore, the team doesn't require micromanagement on our part in order to achieve excellent results."

Work highlights Advised Noble Corporation on all tax matters related to the establishment of a standard specification drilling company in Brazil.

Notable practitioners  

Founding partner Ivan Tauil is particularly noted by market commentators for his experience with clients from the oil and gas sectors. 

Roberta Caneca receives praise from sources for her "excellent service" and her rapid rate of response.

Significant clients BASF, Mitsui, Mir Steel, Rolls-Royce, Dow AgroSciences.

第四等 |

Basic facts about the department - 2 partners
 - 10 other qualified lawyers

What the team is known for The compact team at this mid-sized São Paulo firm advises on the tax aspects of a wide range of corporate transactions but stands out for its expertise in tax litigation, both judicial and administrative.

Strengths (Quotes mainly from clients)

"The firm has highly specialised lawyers with considerable experience and technical knowledge."

Work highlights Worked for Pátria Investimentos on matters of due diligence and tax structuring arising from the acquisition of a domestic coffee producer.

Notable practitioners  

Joint head of department Eduardo Borges focuses his practice on litigation, and regularly leads the team in several high-level deals.

Antonio Carlos Guidoni Filho heads the department alongside Borges. Clients comment: "He is a technical and creative litigator, and is extremely committed to providing us with the best service possible."

Significant clients Odebrecht, HSBC, Fras-le, Ambev, Citibank.

第四等 |

Basic facts about the department - 2 qualified lawyers

What the team is known for Specialises in corporate tax and regularly works alongside the firm's other departments to deliver fully integrated services for its clients, most of which are drawn from the banking and finance sector.

Strengths (Quotes mainly from clients) 

"They provide us with an excellent client service and the results are always exceptional."

Notable practitioners  

Rubens José Novakoski Fernandes Velloza specialises in direct tax and finance taxation. He also has notable experience in civil and commercial law.

Band 4 | Vieira Rezende

第四等 |

Basic facts about the department - 3 partners
 - 9 other qualified lawyers

What the team is known for Compact tax department focusing on consultancy and litigation within the tax arena. Experienced in advising on foreign investment and tax incentive schemes. Often works in tandem with the firm's strong corporate and M&A practice.

Strengths (Quotes mainly from clients)

"The lawyers are experts in the field; they are technically skilled and offer a rapid rate of response."

Work highlights Retained by Companhia Siderúrgica do Pecém to advise on the customs and general tax aspects of its export processing zone operations, worth BRL5 billion.

Notable practitioners  

Clients say department head Luiz André Nunes de Oliveira "is very knowledgeable and considers his clients' needs."

Rafael de Moraes Amorim is praised by market commentators for his "responsive and objective" working style.

Tax litigator Breno Ladeira Kingma is hailed by clients as "a young, proactive and talented partner who understands the issues that affect large companies operating in Brazil."

Significant clients Vale, Tupy, Renova Energia, Norskan Offshore, ThyssenKrupp.

第五等 |

Basic facts about the department - 4 partners
 - 25 other qualified lawyers

What the team is known for Provides ongoing tax consultancy and day-to-day advice to a number of major corporate clients. Also handles tax credit recovery, planning and litigation matters.

Strengths (Quotes mainly from clients)

"They are knowledgeable, understand our business well and have many years of experience in the field."

Notable practitioners

Leandra Guimarães is the key client contact.

Significant clients Anglo American, Localiza Rent a Car, Santander, Holcim, PepsiCo.

第五等 |

Basic facts about the department - 5 partners
 - 12 other qualified lawyers

What the team is known for Well-regarded tax practice regularly retained by high-level clients from the oil and gas industry due to its considerable expertise in this sector. Compact group focusing on tax consultancy, planning and litigation.

Strengths (Quotes mainly from clients)

"They have talented staff and offer timely responses." 

Notable practitioners  

Sources praise Rodrigo Maito da Silveira as being "knowledgeable and client-focused." He has experience in dispute resolution and corporate law.

Marcos Barbosa has been working in the industry for over 25 years. He is recognised by sources for the strength of his tax practice.

Rio-based Tácito Matos is a tax specialist and has expertise in litigation as well as domestic and international tax planning.

Significant clients Shell, Air BP, Canon, São Martinho, Vallourec.

第五等 |

Basic facts about the department - 11 qualified lawyers

What the team is known for Tax issues at this well-established firm are often dealt with as part of its broader corporate and disputes work, including in transactions such as M&A and restructuring, as well as judicial and administrative proceedings. 

Strengths (Quotes mainly from clients)

"The firm has experienced and highly qualified professionals who are able to provide detailed advice on the impact of different arrangements."

Work highlights Advised Efacec on a tax planning matter regarding the termination of an engineering procurement construction contract.

Notable practitioners  

Mauricio de Carvalho Silveira Bueno heads the practice. He specialises in indirect taxation and is a well-respected litigator.

Significant clients Porto Seguro, Sementes Selecta, Saint-Gobain Group, Companhia Brasileira de Distribuição, Neogama Publicidade.

第五等 |

Basic facts about the department - 3 partners
 - 8 other qualified lawyers

What the team is known for Notably experienced in working with international clients from the fashion and engineering industries, acting as counsel on the full spectrum of matters within the tax sphere. 

Strengths (Quotes mainly from clients)

"I appreciate the firm's extensive experience in international tax law, as well as the team's punctuality and flexible approach."

Work highlights Advised leading Italian eyewear manufacturer Luxottica on a broad range of fiscal matters, encompassing direct and indirect taxation, income tax, social contributions, customs duties and transfer pricing.

Notable practitioners  

Sources comment that Paulo César Teixeira Duarte Filho "serves his international clients flawlessly, responding quickly and efficiently to any problems they may have." 

Clients are quick to praise Marcio Carneiro Sperling for his experience in international taxation and his high level of responsiveness.

Head of department Gerd Rothmann is lauded by clients for his availability and in-depth knowledge of tax, contracts and international law.

Significant clients Voith, EDAG Engineering, Mitsubishi Chemical, Hugo Boss, Gianni Versace.

Other Ranked Lawyers 其他上榜律师

Sources are quick to praise Aires Fernandino Barreto of Advocacia Aires Barreto for the depth of his expertise in tax issues related to VAT.

Pedro Guilherme Accorsi Lunardelli of Advocacia Lunardelli is commended by sources for the "outstanding quality of his work." He is well regarded in the market for his knowledge of VAT, tax exemptions and litigation proceedings.

Alcides Jorge Costa of Alcides Jorge Costa Advogados Associados is described as "a point of reference" and is lauded for his great experience in the tax sphere, in both indirect and direct taxation.

Jorge Henrique Amaral Zaninetti of Araújo e Policastro Advogados wins considerable praise from clients: "He conducts tax cases with great care, expertise and strategy. We are truly satisfied."

Clients say Gilberto Ayres Moreira of Ayres Ribeiro Advogados "has deep knowledge of the subject matter and is able to provide innovative solutions."

Clients are full of praise for Renata De Paoli Gontijo of Barbosa, Raimundo, Gontijo, Câmara e Horta Advogados, highlighting her technical ability, attention to detail and "complete devotion" to her work.

Paulo de Barros Carvalho of Barros Carvalho Advogados Associados is a well-known player in the tax arena. He is the founding partner at the firm and has been active in the market for almost 50 years.

José Luis Brazuna of BRATAX - Brazuna, Ruschmann, Piovesan e Soriano Advogados has broad experience in customs and international taxation, and is also well regarded for his litigation practice.

Market commentators reserve high praise for founding partner Cristiano Frederico Ruschmann of BRATAX - Brazuna, Ruschmann, Piovesan e Soriano Advogados, saying he is "outstanding and very experienced." He has notable strength in litigation, international tax matters and issues related to the IT sphere.

Fortaleza-based Hugo de Brito Machado of Brito Machado Consultores Associados is a former judge and is widely acclaimed by market commentators for his authoritative legal opinions.

Eurico Marcos Diniz de Santi of Fundação Getúlio Vargas de São Paulo has been active in the tax sector for over twenty years and leads a number of research projects in the field.

Sources laud Marco Aurélio Greco of Fundação Getúlio Vargas de São Paulo for his influence in the market, particularly in tax planning.

Ives Gandra da Silva Martins of Advocacia Gandra Martins is a highly regarded and experienced practitioner in the tax sphere. Sources describe him as "one of the biggest names in the Brazilian tax market."

Heleno Taveira Torres of Heleno Torres Advogados elicits praise from sources for his expertise in cross-border tax issues. They comment: "He is one of the best in the market for international taxation."

Humberto Ávila of Humberto Ávila Advogados Associados is a highly respected counsel with many years of experience in the field. He is also very active in academic circles.

Market commentators highlight Natanael Martins of Natanael Martins, Mário Franco & Gustavo Teixeira as a skilled and capable litigator in the tax arena.

Sources champion Antenori Trevisan of Mundie Advogados: "He is thorough and proactive, and has deep knowledge of Brazilian tax law."

Alexandre Tadeu Navarro Pereira Gonçalves of Navarro Advogados is commended by sources for his "specialised knowledge and fast, objective responses." He has additional expertise in real estate and commercial law.

Key partner Daniela Melo Fassheber of Pinheiro Guimarães Advogados has almost two decades of experience in the tax arena. Clients comment: "She is spectacular – very intelligent and dedicated to the client."

Sources single out Ricardo Lobo Torres of Ricardo Lobo Torres Advocacia for his many years of experience and for his standing in the market. They add that "he is a first-class professional and much sought after by clients."

Roque Antônio Carrazza of Roque Carrazza Advogados Associados is a highly respected and experienced tax practitioner.

Christiano Chagas Monteiro De Melo of Soares Bumachar Chagas Barros Advogados has broad expertise in tax issues related to capital markets and corporate deals. Clients comment: "He is a dynamic lawyer who understands all of our problems and is always available for the client."

Former tax court judge José Eduardo Soares de Melo of Soares de Melo Advogados is recognised by sources for his experience in the sector and his academic work.

Sources describe José Souto Maior Borges of Souto Borges Advogados as "one of the biggest names in the market." He has many decades of experience in handling tax matters for clients.

Paulo César Ruzisca Vaz of Vaz, Barreto, Shingaki & Oioli Advogados is recommended by clients for his business acumen and helpful manner.

Marcos André Vinhas Catão of Vinhas & Redenschi Advogados is warmly regarded by market commentators for his capabilities in matters of international taxation, and for his high-quality client service.

Foreign Experts

Foreign Experts are individuals with expertise in a different jurisdiction to the one they are based in. These individuals are particularly highly regarded for international and cross-border work. Usually, they will be identified in the jurisdiction in which they are based and in their country of expertise.

Senior Statesman

A 'Senior Statesman' is a lawyer who no longer works hands-on with the same intensity but who, by virtue of close links with major clients, remains pivotal to the firm’s success.

Eminent Practitioners

'Eminent Practitioners' are highly influential lawyers in a particular practice area who, due to managerial or client relationship commitments, are less active in day-to-day work but remain key players in the team.

Other Noted Practitioners

Other Noted Practitioners are individuals who have not yet been ranked but are seen to be active and accomplished in this area of law.

Other Noted Firms

Other Noted Firms are firms that have not yet been ranked but are seen to be active and accomplished in this area of law.