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Tax: BrazilTax: Litigation: Brazil 
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 Tax: Brazil
Tax: Legal Opinions: BrazilTax: Litigation: Brazil
 

Luiz Felipe Centeno Ferraz Of Mattos Filho, Veiga Filho, Marrey Jr E Quiroga Advogados

Contributed by Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga Advogados

Tax 

The dawn of 2011 saw the election of a new federal government in Brazil and Dilma Roussef sworn in as the country's new president. Her election was warmly received by the people and her first few months of office have been largely trouble-free. Nevertheless, she faces an uphill task over the coming years to face down a number of challenges and implement a series of much-needed reforms.

Tax reform has been a perennial problem for successive governments in Brazil and, to date, a series of draft reforms have failed to achieve the necessary political consensus to prosper. The new government has signalled its intention to up the tempo on tax reform and recently announced a four-step draft bill to be sent before the National Congress. The draft bill includes proposed changes to the regime governing taxes on goods and services, payroll taxes, export incentives and changes to speed up the payment of tax credits.

Whilst the tax bill remains a work in progress, infrastructure investment has been another important area of focus during 2011. Further tax incentives were introduced during 2010 and 2011, targeted at projects earmarked as a priority by the federal government. These mainly include infrastructure works related to the World Cup in 2014 and the Olympic Games in 2016.

The extra measures come as a result of the government's acknowledgement that the incentive of running the projects alone might not be enough to secure the required funding, leading to the introduction of tax incentives linked to investment financing.

In addition to looking forward to hosting high-profile events such as the World Cup and the Olympic Games, Brazil has sought to consolidate its reputation as a developer of technology and in manufacturing. To this end, tax incentives have again been applied or amended to foment growth in these areas.

With so many incentive schemes in force, the federal government faces constant pressure to balance payments and contain its deficit, which has led to a more robust stance being taken by the Brazilian revenue service. This in turn has led to a stricter enforcement of tax audits and an increase in tax litigation. Landmark cases in 2011 include judgments on controversial areas such as tax planning and transfer pricing, where the revenue service has not shied away from flexing its new-found muscle.

In a carrot-and-stick approach, the revenue service has complemented its more aggressive stance with more conciliatory measures aimed at promoting dialogue amongst stakeholders. During 2010 and 2011, taxpayers and legal professionals were invited to discuss new rules on tax planning, transfer pricing and thin capitalisation. Should the tax authorities continue to maintain these channels of communication in the long term, then we could perhaps be witnessing the start of a more collaborative relationship between the revenue service and taxpayers.

It is likely that the revenue service will continue to assist the federal government with the preparation of new legislation for 2012. It is expected that this new legislation will focus on tax planning in general, transfer pricing and the tax impact of the relatively new income tax rules and their effect on accounting practices.

Tax payers remain sceptical as to the chances of seeing tax cuts, as the long-term trend has been in the opposite direction with collection replacing planning in the governments strategy, barring those areas in which it wishes to promote growth.

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Tax: Brazil

Due to the number of tables in this section, the editorial is in alphabetical order by firm name.

This São Paulo-based boutique is widely revered for its tax litigation expertise. The team has an impressive track record of handling high-profile and complex tax disputes, often on behalf of Brazilian subsidiaries of multinational corporations. It is undoubtedly one of the "first ports of call for tax litigation in Brazil," according to sources. Much of the firm's success can be attributed to the esteemed Leo Krakowiak, who impresses sources with his well-honed courtroom skills. His son Ricardo Krakowiak has also carved himself a sterling profile in the market. Sources appreciate his in-depth training and clear focus on this area.

Since its inception in 1962, this general practice firm has consolidated a reputation for tax consultancy work. The group regularly advises clients on tax issues related to corporate and M&A transactions. It stands out for its client-oriented approach and clients admire the group's "immediate availability to attend to our needs." São Paulo-based Sylvio Fernando Paes de Barros is a key member of the tax team and is recognised for his practical approach to cases and technical expertise. Enrico Estefan Mannino is a partner in the firm's Rio de Janeiro office and clients praise his dedication and expertise in both consultancy and litigious matters. The firm's work also has an increasingly international flavour and it benefits from a four-strong German desk, which is capably led by Gerd Rothmann.

The tax department of this large firm is a strong support for the firm's 11 offices across the country. As a result, the tax team provides a broad range of services, which includes tax consultancy, tax planning, transfer pricing and the tax aspects of projects and transaction structuring. Its clients span a host of industry sectors and include household names such as MAPFRE and Anglo American. Leandra Guimarães leads the team and is singled out for her experience in the sector.

Well known for its strong supporting role to the firm's first-rate M&A department, the tax department at the firm has truly come into its own in recent years. It is increasingly seen on some of the market's most noteworthy mandates. Highlights include acting as local counsel to London-based private equity investment group Apax Partners in relation to its acquisition of a 54.25% controlling interest in TIVIT, a leading Brazilian IT services and business process outsourcing provider. The firm advises clients on a wide range of tax issues, across a number of sectors and also handles a high volume of contentious matters. Sources say: "The lawyers are excellent; aggressive in the right measure and completely dedicated to their clients' cause and business interests." Sources point to Luciana Loureiro Terrinha Palma de Jorge as an associate with a bright future and a strong awareness of clients' needs. Alexandre Seguim recently left the firm.

This nine-strong team is well-known for consultancy work and is also gaining a reputation for its expertise in tax litigation. It primarily advises clients on tax structuring and planning related to corporate and financial transactions. It is also increasingly involved in consultancy work related to the telecoms, IP and IT sectors. In recent highlights, it advised a company on the tax aspects of its software licensing agreements, as well as assisting another major client with the tax implications of the sale of literary, artistic and scientific works via the internet. Ricardo Barretto Ferreira da Silva and Alyne Machado Silverio de Lima are the department's primary contacts for clients.

Since publication, Celso Grisi has joined Grisi, David e Aniceto Advogados Associados

Since publication, Daniel de Aguiar Aniceto has joined Grisi, David e Aniceto Advogados Associados

This firm's investment in its tax department is paying off and it continues to expand its presence in the market. The tax team has an impressive 75 lawyers handling a wide array of consultancy and litigation work and it is increasingly a reference point for international clients operating throughout Latin America. It advised Construtora Queiroz Galvão on establishing a new business entity in Panama and acted as Latin American counsel to San Antonio Internacional regarding tax issues related to Latin America-wide business restructuring. "The team stands out thanks to its personalised service and the fact that the lawyers are always very well informed about legislative decisions and trends in the market," enthuse sources. The firm's membership of the ALAE, Miranda and Lexwork alliances has also helped the team establish strong working relationships throughout Latin America, Africa, Europe, the USA and Asia. Sources hail Luiz Gustavo Bichara as an "entrepreneurial and business-minded tax lawyer." He leads the department and is praised for well-honed technical expertise. Sandro Machado dos Reis is a key member of the tax litigation team and is a firm favourite with clients.

This firm has consolidated a first-class market reputation in the tax arena. The firm's combined talents in tax and real estate regularly sees the two departments work in tandem on some of the country's most significant real estate transactions. "I would highly recommend the firm to any real estate development company requiring Brazilian real estate or tax expertise," attest clients. Its alliance with DLA Piper has also undoubtedly broadened and strengthened its tax expertise in a number of different sectors. International clients highlight the team's client service and language skills. Guido Vinci is one of the department's most visible names and is held in high esteem for his client-oriented approach. Ana Luiza Martins is the primary contact for tax litigation matters.

This tax practice is split between the firm's offices in São Paulo and Rio de Janeiro and also benefits from the support of its lawyers in Brasília and associate office in Lisbon. The nine-strong team handles tax consulting, international tax planning, tax structuring and litigious work across a range of industries. It advised leading Brazilian retailer Casa e Vídeo Rio de Janeiro on the corporate and tax restructuring of its business operations. In litigation highlights, the team successfully represented TIM Brasil Group in a case brought to prevent VAT being levied on the company's international roaming services provided to foreign telecom companies' customers. Practice head André Gomes de Oliveira is praised for his ability to "perfectly coordinate international know-how and provide an incomparable service." He is based in the firm's Rio office and is the chairman of the tax committee of the British Chambers of Commerce in Rio de Janeiro.

This full-service firm offers clients an impressive 80-strong tax team providing both consultancy and litigation services. The team takes a four-pronged approach, with separate teams handling corporate tax, VAT, customs and anti-dumping and social security matters. The team advises local and international clients across a wide range of industries, and has also been acting for an increasing number of private equity investment funds in relation to acquisitions and the restructuring of their business operations in Brazil. Practice head Oswaldo Leite de Moraes Filho wins unanimous client praise: "We are fully aware that our company is not the firm's largest or most important client, but it would be no exaggeration to say that Oswaldo's dedication and courtesy makes us feel as though we were his only client." Eloisa de Almeida Rego Barros Curi is highlighted for her particular expertise in tax matters relating to the financial and insurance markets.

This firm is a growing force in the Brazilian tax market and has gained considerable international exposure through its association with Spanish legal giant Uría Menéndez. The eight-strong team handles a high volume of advisory work and is also gaining prominence in litigation circles. It advises a wide range of clients in the technology, infrastructure and corporate sectors. Cristiano Frederico Ruschmann is the firm's best known tax expert and impresses international clients with his ability to "pay attention to even the smallest of details."

Over more than four decades this firm has become one of the country's household names for tax litigation. It also handles a high volume of consultancy work and is home to experts in tax planning and VAT and specialists in devising tax strategies and structures for complex transactions. Much of the firm's success can be attributed to tax expert Hamilton Dias de Souza. He excels in both tax advisory and litigation cases and is the backbone of the team. He is capably supported by tax litigation specialist Mário Luiz Oliveira da Costa, who stands out for his knowledge and dedication to the sector.

This firm is gaining ground in the local tax market. Its practice covers the full range of tax issues, including transfer pricing, tax planning, anti-dumping, tax litigation, as well as administrative and judicial proceedings. It also has specialists in tax matters related to bank transfers, regulations and bankruptcy and restructuring transactions. Antonio Amendola stands out for his demonstrable dedication to clients' needs. Sources also highlight his experience of the international market, having previously worked as a tax associate at PwC in New York and having undertaken postgraduate studies at Cornell Law School.

Since its foundation in 1990, this firm has maintained a strong focus on tax matters. It has five offices across the country and benefits from alliances with lawyers and law firms throughout Latin America and the USA. The large team has the resources and capacity to work on several large-scale cases simultaneously. It regularly provides legal opinions to international companies and advises them on a wide range of tax aspects including tax compliance, tax planning, and corporate tax. On the litigation side, it represented an international company in a dispute arising from an infrastructure project which was recently carried out in Brazil. Fernando Antonio Cavanha Gaia, Severino José da Silva and Henrique Gaede are the primary contacts for tax matters.

This firm was established relatively recently and its 11-strong team is fast becoming a force to be reckoned with in the tax arena. It has garnered considerable experience in recent years and is recognised for its "strong working relationships with international clients and with companies looking to establish themselves in Brazil," according to sources. It regularly works with international law firms and is advising K&L Gates LLP on Brazilian customs legislation and Mercosul matters for Research In Motion (BlackBerry). Clients are also quick to praise the lawyers' language skills: "The tax team works very closely with our holding company in Europe and the lawyers have the language skills and proactivity to do this directly, without any need to liaise through us." Henrique De Oliveira Lopes da Silva leads the team and is recognised for his profound knowledge and excellent client service skills. Victor Polizelli is another key member of the team and stands out for "his high level of technical expertise and responsiveness." He speaks fluent German and advises a number of German clients.

In light of the firm's long-standing reputation in arbitration and international trade, it is unsurprising that it is also gaining prominence for its work in the tax sector. The group has a broad practice, which includes national and international tax planning, transfer pricing, due diligence and administrative and judicial litigation. It also regularly works in close collaboration with the firm's corporate and projects departments on a variety of transactional and infrastructure deals. The group represents a number of important multinationals and recently advised FNAC Brasil on the tax implications of recent legislative changes introduced by the local authorities in São Paulo. Marcos Ribeiro Barbosa and Rodrigo Maito da Silveira lead the department and are the main contacts for clients. In November 2011, L.O. Baptista joined forces with Schmidt, Valois, Miranda, Ferreira e Agel, further increasing the firm's strength and versatility.

This firm has a dedicated tax department, noted for the specialisation of its lawyers. Luís Eduardo Schoueri is a key player in this practice, with highly regarded expertise in transfer pricing and international taxation. Alexandre Siciliano Borges is another strong name in this group. He is described as an "exceptional and a very studious and meticulous lawyer." Luciana Angeiras impresses clients with her “great efficiency and dedication.”

This “highly qualified and client-oriented” team advises on an array of transactional and contentious tax matters related to M&A, capital markets and banking. International taxation is one of its strong suits and the firm’s co-operation with Linklaters is also an advantage to its cross-border activities. As an example of its overseas capabilities, Lefosse advised Ambev on its acquisition of 15% of the assets of Cerveceria Regional in Venezuela. Practice head Gustavo Lian Haddad is famed for his broad knowledge, practical approach and ability to attend to multinational clients' needs. Ricardo Bolan is praised for his “profound tax knowledge,” as well as his “ability to discuss complex issues in English.” Marcos Carvalho and Joana Liu are “dedicated lawyers with strong business acumen.”

This seven-strong team has consolidated its position in the market and routinely advises clients on transfer pricing, international taxation, international trade, social security audits, due diligence and tax aspects of M&A and finance transactions. It is also capably supported by the firm's litigation department, which handles both administrative and judicial tax proceedings. It acts as counsel to German-owned Steel do Brasil Participações in relation to all day-to-day issues and is assisting it with pre-IPO organization and several acquisitions in the Brazilian mining sector. Isabela Schenberg Frascino co-heads the department and is specialised in national and international tax planning.

This tax department houses nine lawyers with expertise in tax consulting, tax planning and administrative and judicial tax litigation. It advises a host of multinational clients and notably acted as lead tax counsel to global education company Pearson in connection with its strategic partnership with Brazilian listed company Sistema Educacional Brasileiro (SEB). The agreement will see Pearson acquire SEB's learning systems division for approximately USD505 million, allowing it to develop educational products and services in the Brazilian market. Clients value "the team's ability to convey what are sometimes complex ideas about Brazilian law in a straightforward manner." Bruno Macorin Carramaschi leads the department and is the primary contact for clients.

This firm has a strong tax practice that covers a wide range of matters, including the full spectrum of tax consultation on areas such as transfer pricing and transactions, as well as carrying out litigation work. The group has a strong accounting background that is seen by clients as a key advantage. The team impresses sources with its “pragmatism, practical experience and availability: its lawyers have a broad vision of issues and are able to present innovative solutions.” Luís Rogério Farinelli and Julio de Oliveira lead the group and win praise for their expertise and commercial acumen. Antonio Carlos Salla is praised for his knowledge of indirect taxes, while Carlos Augusto da Cruz is recommended for his pragmatism. Isabel Bertoletti is a standout name on the consulting side, with an “impressive intellectual capacity that combines great judicial knowledge with her accounting background.” Cristiane Magalhães is “fantastic for income tax: she is objective and a quick thinker.” Fabia Elaine Moreira Azevedo is a skilled lawyer praised for her responsiveness.

Since publication, Marcio Roberto Alabarce has moved in-house to Companhia de Concessões Rodoviárias (CCR).

Clients are impressed with the consistent quality of this player: “Lawyers are always available and provide us with in-depth analyses.” The firm has a team of 12 partners and over 53 associates with the expertise to advise on a multitude of consulting and litigation issues. Recent highlights include advising Petrobras on Braskem’s acquisition of Quattor. Celso Costa led the team involved in the aforementioned deal. He is an "outstanding practitioner, able to combine his knowledge of legal, business and accounting aspects to the benefit of his clients.” Raquel Novais has well-rounded expertise and is praised by clients for her speedy solutions. Daniella Zagari Gonçalves is noted for her skills in tax litigation and Fernando Tonanni impresses clients with his dedication. Marcelo Paulo Fortes de Cerqueira and Paulo Fernando Souto Maior Borges are skilled young associates who are highly rated by clients.

This firm is recognised for its strong track record in providing advice on tax aspects of complex corporate and M&A transactions. As a result, it regularly provides tax advice to big-name clients in the corporate, pharmaceutical, automobile, real estate and financial sectors. Juliano Rotoli Okawa is a key member of the tax team and is experienced in tax planning and tax issues relating to the structuring of corporate transactions.

This firm's name has become a byword for tax expertise in Brazil. The tax department has impressive experience and a strong team of skilled lawyers. According to sources, this boutique has an “impeccable litigation practice and credible consulting expertise.” Ricardo Mariz de Oliveira is one of the most renowned tax lawyers in the country and a reference point in the market. He is recommended for his “razor-sharp intellect.” João Francisco Bianco is equally recommended for his enormous level of knowledge and is heavily involved on the consulting side. Roberto de Siqueira Campos is another tax expert who makes an invaluable contribution to this team.

This pragmatic and commercially minded practice offers a wide range of advisory and contentious tax services, covering corporate taxes, VAT and administrative and judicial litigation. The team of 60 lawyers is highly recommended for its “proactivity and ability to explain complex issues in a clear and concise manner.” Roberto Quiroga Mosquera is one of the key names within this team. He is commended for his “in-depth knowledge and excellent communication skills.” Pedro Luciano Marrey Jr is described as a “lawyer of the highest level, whose consulting abilities stand out.” Luiz Felipe Centeno Ferraz is another great addition to the consulting side of this team. Andréa Bazzo Lauletta and João Marcos Colussi stand out due to their “proactive approach and ability to anticipate clients' needs.” Maria Isabel Tostes da Costa Bueno and Glaucia Maria Lauletta Frascino are also recommended for their "tax law know-how as well as for their accessibility, and efforts to keep clients constantly updated.” Alessandro Amadeu da Fonseca impresses clients with his consulting services, while Renata Correia Cubas is commended for combining legal knowledge with well-honed business skills.

Since its inception in 1996, this firm has grown to become an important player in the market and is increasingly praised for its tax expertise. The team advises clients on tax compliance, due diligence, tax structuring, risk assessment, international taxation, income tax, VAT, and international trade matters. It acts for high-profile corporations across a wide range of sectors and international clients are impressed by the lawyers' strong command of English. In recent highlights, the team counselled a global brewing company on the tax implications of its USD7 billion acquisition of the Brazilian and Mexican subsidiaries of a global beer business. Newly appointed partner Antenori Trevisan stands out for his knowledge and ability to "explain complicated tax issues clearly and explain them in layman's terms."

This department's main strength lies in advising clients on tax matters related to M&A, financial and capital markets transactions. The group dedicates much of its time to consultancy work and has specialists in derivatives, tax planning and tax structuring. It also represents both local and international clients in a large number of administrative and judicial tax proceedings. It advised Brazilian publishing house Editora Globo on the tax implications of its joint venture with Condé Nast Brasil Holding, a subsidiary of Advance Magazine Publishers. Daniela Melo Fassheber is a key member of the department and is praised for her responsiveness and "profound knowledge of the tax field."

This market leader's tax practice offers tax consulting and litigation services of outstanding quality. On the litigation side, clients acknowledge its high success rate even in the most challenging of cases. Its tax planning and transfer pricing expertise are further strengths and the team is well known for its prowess in transactional work. Sources say: “Pinheiro Neto is impeccable in terms of quality. Lawyers are really experienced and, in addition to the technical capacity, they have the necessary business acumen to go the extra mile.” Ricardo Becker is particular recommended for his transactional expertise. Luciana Rosanova Galhardo is highly praised for her consulting and litigation skills. Sources say she is an “icon in tax law in Brazil.” José Roberto Pisani is a respected tax litigation lawyer and Carlos Henrique Bechara is hailed for his "knowledge and dedication.” Luiz Roberto Peroba Barbosa wins praise for his wide vision of the legal tax world. Sources say Marcelo Marques Roncaglia offers services of unique quality and “always anticipates clients' needs.” Giancarlo Chamma Matarazzo is highly recommended for his expertise in direct tax.

This firm is widely respected for its tax expertise and is hailed for its "tailor-made service, high-quality work and consistent compliance with deadlines." This department consists of 11 partners and 42 associates and offers the full range of tax advice, focusing on national and international tax planning, tax compliance, risk assessment, administrative and judicial tax litigation and advice on tax aspects related to transactions, primarily in the energy, regulatory and finance sectors. Clients stress that the group has the know-how and resources to handle a number of large-scale cases simultaneously. Sources highlight Cristiano Augusto Ganz Viotti's pragmatic and assertive approach to cases, while João Dácio Rolim is praised for his strong track record and extensive knowledge of the sector. Gilberto Ayres Moreira is also singled out as a key member of the group and is involved in many of the department's most high-profile cases. Marciano Seabra de Godoi has a growing tax practice and is a firm favourite with clients. "It is hard to find many other lawyers who have his level of tax knowledge," enthuse clients.

“According to clients, the firm combines the strong academic background of its founders with the high-quality work of all its lawyers.” This tax boutique has a stellar reputation in the market, and in addition to its undisputable legal expertise, wins praise for its "timely responses and availability.” The group recently advised Vale drafting a legal argument defending the non-taxation of real estate property lying under and adjacent to railways, which has been accepted as setting a legal precedent. Sacha Calmon Navarro Coelho led the elaboration of the aforementioned work. He is a renowned tax lawyer, highly praised for his legal opinions and for his remarkable contribution to academia. Misabel Abreu Machado Derzi is an “authority in tax law in Brazil." She is greatly sought-after for legal opinions and is a respected name before the courts. Eduardo Maneira is a skilled litigator, praised for his “dedication, and for always delivering.” Igor Mauler Santiago and André Mendes Moreira are equally respected for their technical know-how.

This firm offers clients impressive geographical coverage in Brazil and is fast increasing its market profile due to its skills in tax advice and tax litigation. The tax department has a noteworthy client roster and impresses sources with its ability to "attend to 100% of clients' needs." The tax group has experienced a number of changes in recent times, merging with tax boutique Advocacia Lunardelli in October 2010, and demerging again once it became clear the new arrangement wasn't working out. Jorge Henrique Amaral Zaninetti then joined the firm in September 2011 as head of the tax litigation group. He benefits from his prior auditing experience at KPMG and Ernst & Young and specialises in foreign trade and VAT matters. Maucir Fregonesi Jr impresses clients with his diligence and business acumen, while practice co-head Richard Edward Dotoli stands out for his expertise and in-depth knowledge of the sector.

Since publication, Pedro Guilherme Accorsi Lunardelli has joined Advocacia Lunardelli

This busy tax department offers a broad range of services and plays a key role advising on the tax aspects of the firm's numerous M&A and project finance transactions. Sources draw attention to the team's strong sense of loyalty to its clients: "Our internal team changes but we never lose the close working relationship that we have with Souza Cescon," enthuse satisfied clients. In a recent highlight, it assisted Portugal Telecom-GPTI with the tax issues related to a share merger with Dedic, a wholly-owned subsidiary of Portugal Telecom, in order to consolidate its business operations in Brazil. It also lists a host of household Brazilian names as clients, including TIVIT, who it advised on its USD512 million sale by Votorantim Group and Pátria Investimentos to private equity fund Apax Partners. Founding partner Roberto Barrieu co-heads the tax department alongside Paulo Bento. Clients say: "Both lawyers are very solution-driven: they understand clients' needs and always try to find appropriate solutions for clients."

This firm is increasingly sought-after for its tax expertise and provides tax assessment, planning and compliance advice and represents clients in both judicial and administrative tax proceedings. In light of the firm's prominence in the oil and gas sector, it is unsurprising that the tax department advises a large number of energy and oil companies on the tax side of their business operations. The firm's association with Mayer Brown makes it a natural choice for international tax advice and it regularly acts as local counsel to foreign companies carrying out M&A and finance transactions and joint ventures. Its first-rate client list includes Cameron Corporation, Weatherford Industria e Comércio – Weatherford Brasil, Baker Hughes Equipamentos and Noble Corporation. Ivan Tauil stands out for his experience of tax issues related to the oil and gas sector. Clients offer effusive praise for Mayra Mega Itaborahy, who "understands her clients' business and can articulate the intricacies of local laws in a way that foreign clients can readily comprehend." Since publication, Christiano Chagas Monteiro De Melo has joined Soares Buchamar Chagas Barros Advogados.

This legal powerhouse has a large dedicated tax team and advises a varied range of local and international clients. The department is regularly called upon to advise on the tax aspects of the firm's most high-profile mandates. In recent highlights, it acted as Brazilian counsel to FEMSA in connection with the sale of Cervejarias Kaiser Brasil to Heineken. Practice head Ana Cláudia Utumi led the team advising FEMSA and is highly recommended for her experience and knowledge of international tax matters. Since publication, Jorge Henrique Amaral Zaninetti has joined Siqueira Castro Abogados and Gabriel Sister has moved to Ernst & Young Terco.

This large tax department handles a high volume of consultancy and litigation work and benefits from the additional resources and expertise gained through its association with international law firm Baker & McKenzie. The team advises both local and international corporations on tax planning, tax efficient structures, transfer pricing and regularly represents clients in administrative and judicial tax proceedings. It has an impressive international client base which includes high-profile names such as Toyota, and it is consistently highlighted as "one of the best options for tax advice in Brazil." Simone Dias Musa leads the consultation side of the practice and clients value her strong working relationships with the authorities and "her unquestionable technical expertise." Paulo Sehn manages the tax litigation team and is widely praised for his negotiating skills. Clarissa Giannetti Machado impresses sources with her "dual legal and business vision," while Maria Fernanda Furtado Fernandes displays particular talents in tax matters related to the oil and gas sector.

Sources unanimously acknowledge this firm as a top choice for handling the tax aspects of high-profile transactions and complex litigation. The team comprises over 38 lawyers, described as “attentive and responsive. They are very reliable and client-focused.” João Dodsworth Cordeiro Guerra and Carlos Alberto Ulhôa Canto are outstanding lawyers, commended for their "understanding of clients' needs and quick and precise methods.” Gustavo Brigagão is highly regarded for his skills in both consulting and litigation. Rubem Tadeu Cordeiro Perlingeiro is highlighted as another key member of the department and Rodrigo Brunelli Machado is recognised as an attentive and business-oriented lawyer. Antonio Carlos Garcia de Souza is described as a skilful tax litigator, while Luiz Felipe Carvalho and Eunyce Porchat Secco Faveret impress clients with the quality of their work and strong track record in the sector.

This legal powerhouse has a large tax team of 40 lawyers based at its offices in São Paulo, Rio de Janeiro, Brasília, Ribeirão Preto and Porto Alegre. It has a broad practice which covers the full range of tax consultation and litigation and it is a regular port of call for both local and international clients requiring tax advice for joint ventures and projects in the oil and gas and corporate spheres. Recent highlights include advising the local subsidiary of Philip Morris on tax efficient structures to enable the company to directly source tobacco leaf from tobacco farmers in the south of Brazil. The team also advised Lupatech on the tax planning and corporate structuring related to the chartering and operation of two light workover units in the context of a project with Brazilian energy giant Petrobras. Clients say: "I would highly recommend Veirano to other companies looking for Brazilian tax counsel to gain a better understanding of the complex tax rules in Brazil." Senior partner Ian Muniz manages the department and co-ordinates the tax teams across the firm's five offices. He splits his time between Rio de Janeiro and São Paulo and benefits from considerable experience in the market, having previously managed the legal department at Arthur Andersen. Abel Amaro is in charge of the tax team in São Paulo and is recognised as an expert in excise tax and VAT. Márcio Calvet Neves is a key partner in the Rio office and is praised for his "fantastic availability and great business vision." Also based in Rio, André de Souza Carvalho is lauded for his skills in international taxation, while André Luiz de Castro Martins is regarded as a rising star in the department. Henry Lummertz manages the tax team in Porto Alegre and is well regarded for his tax litigation expertise. Rio de Janeiro-based Emmanuel Biar de Souza is also singled out by clients as a key member of the litigation team. João Agripino Maia returned to the firm in April 2011, having consolidated his tax planning and transactional expertise at several of the country's other leading law firms.

The tax department at this firm covers the full spectrum of tax litigation, tax consulting, international tax and tax planning. It advises a growing number of clients in the agribusiness, energy, finance and IT sectors. Clients say: "Its lawyers take a particularly efficient and focused approach, have a strong business vision and are extremely goal-oriented." Practice head Antonio Carlos Guidoni Filho's technical expertise and pragmatism inspire great confidence in clients. He is capably supported by associate André Ricardo Lemes da Silva. "Both lawyers have extensive knowledge of the energy sector and this makes us confident in retaining them as our external counsel in decisive moments," enthuse clients.

Since 1993, this firm has offered a broad service which includes advice on tax assessments, tax planning, tax-related aspects of administrative and commercial agreements and contracts and representation in administrative and judicial tax proceedings. It is particularly well regarded for its knowledge of financial transactions tax. Sources highlight Andrea Nogueira Neves's in-depth knowledge and experience of the tax sector. She previously worked as a tax consultant at a leading auditing firm and is a former legal director of the Brazilian Institute of Certification of Financial Professionals (IBCPF).

This firm enjoys a good reputation in the market and also benefits from strong lusophone links via its relationship with Teixeira De Freitas, Rodrigues e Associados in Portugal and Angola, and Ferreira Rocha & Associados in Mozambique. The tax department advises on the full spectrum of tax compliance, planning, administrative and judicial tax litigation. It also habitually works in tandem with the firm's corporate, oil and gas and finance teams to provide a comprehensive service for all manner of transactions in these sectors. Clients value the team's well-honed tax expertise. Luiz André Nunes de Oliveira co-heads the department alongside Breno Ladeira Kingma. Nunes de Oliveira has invaluable consultancy experience in the sector, having held several in-house positions at Vale. Clients single out Ladeira Kingma as a tax litigation expert, highlighting that "in spite of his youth, he stands out because he is highly qualified and experienced." Mariana Longo Solon Pontes is another key member of the group and specialises in administrative and judicial tax litigation.

This firm has one of the most established tax practices in the country, recommended both for its exceptional degree of specialisation and “undisputable technical quality.” The team comprises 23 lawyers noted for their ability to handle the most complex consulting and litigation work. It recently advised CEMIG on the acquisition of a direct and indirect participation in LIGHT – Rio de Janeiro State Energy Distribution Company. Alberto Xavier remains an authority in the tax arena, with special recognition for his understanding of international taxation. Roberto Duque Estrada combines outstanding know-how both on the consulting and litigation sides. In addition, he is "very accessible and amicable." Renata Emery is a young partner with a strong transactional profile.

José Souto Maior Borges of Souto Borges Advogados is highly recommended for his legal opinions on tax matters and is extremely knowledgeable of the tax aspects of the Mercosur treaties. He is also well versed in tax treaties and free trade matters. Roque Antônio Carraza of Roque Carraza Advogados Associados is considered to be one of the foremost tax experts in Brazil and is highly regarded for his legal opinions. Sources hail Paulo de Barros Carvalho of Barros Carvalho Advogados Associados as "one of the most important lawyers in tax law in Brazil." He is regularly retained by important clients for his expertise. Venerable tax expert Hugo de Brito Machado of Brito Machado Consultores Associados is praised for his long-standing tax experience and is a clear reference point in the Brazilian tax market. Sources also highlight Ives Gandra da Silva Martins of Advocacia Gandra Martins for his encyclopaedic tax knowledge and strong track record in the sector. Alcides Jorge Costa of Alcides Jorge Costa Advogados Associados has enviable experience in the market, having served as a judge for São Paulo's Taxes and Interests Tribunal for almost a decade, and also due to prior experience as a legal adviser to the IFC on the subject of international lending to Brazil. Marco Aurélio Greco is a highly respected professor at Fundação Getúlio Vargas de São Paulo, one of the most prestigious universities in Brazil. He is a respected, published authority on local tax legislation. Ricardo Lobo Torres is a key tax specialist at Ricardo Lobo Torres Advocacia and is recognised for providing insightful legal opinions on tax matters. Paulo César Ruzisca Vaz founded tax boutique Vaz, Barreto, Shingaki & Oioli Advogados and is a clear reference point in the market. Sources draw attention to Mário Junqueira Franco Júnior of Martins, Chamon e Franco Advogados for his strong technical expertise and highlight him as a star of the future. Sources commend Humberto Ávila of Humberto Ávila Advogados Associados for his in-depth knowledge of the tax arena. Aires Fernandino Barreto is a well-regarded tax specialist at Advocacia Aires Barreto and impresses sources with his academic credentials. Sources highlight tax litigation expert Eduardo Borges of Prado Borges Advogados for his "professional synergy" and his skills in representing clients in administrative and judicial tax proceedings. Edvaldo Brito of Edvaldo Brito & Advogados Associados is also highly regarded for his legal opinions on tax matters and is an established name in the market. Eurico Marcos Diniz de Santi is another strong reference point for tax matters at Fundação Getúlio Vargas de São Paulo, where he founded Núcleo de Estudos Fiscais. José Eduardo Soares de Melo of Soares de Melo Advogados is a key figure in the market and well versed in tax matters. Heleno Taveira Torres is a highly regarded lawyer at Heleno Torres Advogados and has a strong academic profile in the market. Silvania Tognetti joined Brasil, Pereira Neto, Galdino e Macedo Advogados – BPGM in August 2010. She is well regarded in the market for her expertise in tax consultation and litigation and is focusing her efforts on expanding the firm's tax practice. Fernando Salvia of Coimbra, Focaccia, Lebrão e Advogados (CFLA) emerges as a young talent in litigation and clients highlight his "impressive technical capacity." Since publication, Christiano Chagas Monteiro De Melo has joined Soares Buchamar Chagas Barros Advogados. Sources highlight his "technical knowledge and practical approach to resolving problems faced by in-house tax departments." Celso Grisi and Daniel de Aguiar Aniceto departed BKBG to form Grisi, David e Aniceto Advogados Associados. Sources admire Grisi for his technical expertise, while Aniceto is highlighted for his skills in contentious matters. Pedro Guilherme Accorsi Lunardelli is back at the helm of an independent Advocacia Lunardelli, following an unfruitful experiment uniting his tax boutique with Siqueira Castro. He is singled out as "a lawyer with an excellent reputation in the Brazilian market."

Future Events 

6th June: Chambers USA General Counsel Seminar: New York

7 June 2012: Chambers USA Awards for Excellence 2012, New York




7 June 2012: Launch of Chambers USA 2012


17 September 2012: Chambers Latin America Awards for Excellence 2012, Miami


25 October 2012: Chambers Bar Awards 2012

 

Chambers News

10 May 2012: Chambers Europe Awards for Excellence, Amsterdam