Brazil

Abreu Goulart Santos Freitas & Megozzi Advogados is a tax boutique from Rio de Janeiro that focuses on tax litigation matters. It offers services including direct and indirect taxation, transfer pricing, judicial and administrative litigation, tax planning, due diligences, and tax credit recovery. The team’s clientele comes from a wide range of sectors, including the retail industries, insurance, and education.

One recent example of its work saw the firm handle more than 300 new cases with an aggregate value of over R$3 billion. Further details of cases remain confidential.

During the research period, the firm welcomed Rodrigo Escobar and Guilherme Maia from Magro Advogados, as well as Joana Gayoso from Osório Fernandes Advogados and Raphael Aguiar Mihaliuc from Barros de Arruda Advogados.

Founded by Luciana Aguiar, Alexandre Monteiro and Francisco Lisboa Moreira, former partners of Bocater Camargo Costa e Silva Rodrigues Advogados, ALMA Law focuses mainly on tax, regulatory (especially within the energy sector), corporate, capital markets and M&A matters. The firm is engaged in complex national and cross-border cases, both on litigation and advisory matters. Its specialty focus is on assisting clients from the renewable energy sector.

During the research period the team assisted Vibra Energia in various disputes before the Brazilian tax tribunals and administrative authorities. One instance includes representation in a judicial dispute aiming to recover ICMS (VAT) collected in advance by the company. The firm developed a judicial strategy to recover the ICMS collected in advance over a presumed basis (tax substitution) when the arbitrated calculation basis was higher than actual sales price. Additionally, the team was hired to challenge the constitutionality of a fine imposed in case compensation by a taxpayer (between tax credits and liabilities) is not admitted by Federal Government.

Client feedback

“I believe their main attributes are related to their unique knowledge of the market and on the way we do business. They are more like long-term partners as they usually anticipate ways to maximise our efficiency. Their view on the business is actually what differentiates them from the others.”

“ALMA Law, including their partners Alexandre Monteiro, Luciana Aguiar, Francisco Lisboa and Luiza Rangel, knows deeply our business and are a type of firm that combines (i) technical quality as well as (ii) partnering up with their clients. They can anticipate issues and find different opportunities for us in our long-standing relationship.”

“A very strong team which is composed by talented and engaged professionals. Moreover, ALMA is always thing ahead of the time. In fact, ALMA regularly provides singular solutions to complex cases.”

“Exceptionally strong in TP/international corporate tax.”

“Fantastic team, good prices, always ready.”

“Excellent technicians, fast, great price, good at consultancy and litigation. They are also strong in accounting aspects.”

The tax team at Almeida Advogados consists of highly experienced tax litigators. The firm regularly defends and represents clients in tax against State and Federal authorities. Its work includes challenging tax infraction notices (tax assessments) and helping clients file lawsuits that could set important precedents for the tax code. In addition, the practice covers administrative and judicial tax disputes regarding direct and indirect taxes including ISS, ICMS, IOF, PIS and COFINS, etc. Finally, the firm assists clients in tax planning and advisory.

During the research period the team represented Grupo RB by filing a lawsuit against the Federal Revenue Service of Brazil to demonstrate the violation of tax rules. The assistance helps guarantee the refund is performed.

Client feedback

“Almeida Advogados are good tax advisors that have helped us with our questions and requests.”

“The law firm provides new access to tax benefits when applicable to the oil business and is fast to follow through. Good knowledge on tax law. Always courteous.”

“They are very attentive on giving us direct feedback. They also always bring new solutions.”

“The legal office has great expertise in our sector, allowing the company to make safe and assertive decisions about tax incentives and the possibility of discussing the most correct and advantageous taxation for the market in which the company operates.”

Almeida Prado Marx Tesser & Flor Advogados is based in Manaus and Sao Paulo. The firm specialises in tax law, dedicated to the creation of new theses related to the Manaus’s Free Trade Zone, Western Amazon, and other Free Trade Areas. For more than a decade, it’s been working on recovery and reduction of tax liabilities, defending the rights of large taxpayers in Amazonas on matters related to direct and indirect municipal, state, and federal taxes.

The team was recently hired to provide a legal solution to Sociedade Fogas. The objective was to recognise the company’s right to deduct PIS and COFINS credits on essential and relevant supplies, as well as reduce the income tax burden. This case is ongoing.

During the research period the firm welcomed two new lawyers: Alessandra Bosquê from DD&L and Delcilene Rebouças from Caminha Advogados.

The tax department of Amaral Lewandowski Advogados was formed in 2019 with a focus on tax controversy both for the administrative (Federal, State and Municipal levels) and judicial levels (Federal and State courts). It also assists clients in responding to tax audits, to negotiate and offer compromises with tax authorities to reduce tax debts. Enrique Lewandowski is the key tax partner.

In one recent example of its work, the firm expanded its client base to include a significant player in the coffee market. By doing so, the team demonstrated its experience in administrative litigation in the food and beverage sector. The specific client is confidential. The past year also witnessed noteworthy cases in indirect taxation.

During the research period the firm welcomed Davi Lucena as an attorney.

Client feedback

“They are very careful with the demands that really make sense for the company.”

Araújo & Policastro Advogados was created in 1962. Partner Sylvio Fernando Paes de Barros Jr specialises in the practice areas of tax, litigation and arbitration. The department is active in the areas of general corporate tax and tax controversy. Its clients come from sectors such as agrobusiness, pharmaceutical, electronics and financial services.

Details of the firm’s work and clients remains confidential.

During the past year Helena Soriani left for Machado Meyer Advogados. However, the team welcomed Maria Carolina Lopes Torres Fernandes as an associate from Brazuna Ruschmann e Soriano Sociedade de Advogados.

The tax team of Araúz Advogados consists of a tax litigation department and a tax planning and consulting department. It supports clients in issuing legal opinions on tax doubts, analysing and structuring plans with the objective of minimising the tax impact on its operations. Key partners Gabriel Placha and Rodrigo Borba cover tax litigation and tax advisory respectively.

Details of the firm’s work and clients remains confidential.

Arrieiro Advogados is led by the Eduardo Arrieiro. The firm provides legal services to investment funds, companies, partners, shareholders, managers, family businesses, an startups, among others, in tax consulting, tax litigation, corporate law, M&A, business and succession planning, corporate governance, contracts, strategic litigation and arbitration.

During the research period the firm advised Associação Mineira de Supermercados (AMIS) by providing tax advice and defending the interests of the association against unconstitutional collection. The team was successful before the Court of Appeals of the State of Minas Gerais, in the second degree of jurisdiction. Its actions benefit hundreds of members, with values estimated in more than R$10 million.

Client feedback

“We always consult our advisors on any situations outside conventional business, and all times find combined solutions together with Arrieiro Papini Advogados, fast and effectively.”

“Competent and up-to-date professionals. Are good communicators, agile and efficient. Has a fair fee.”

Founded in 2011, ASBZ is a multidisciplinary law firm capable of offering legal solutions. The tax department adopts a systemic view that analyses tax issues with macroeconomic, operational, accounting, competition, financial, reputational, statistical and fiscal international issues. The team is focused on bringing innovation to the market.

During the research period the firm, in association with Neoway, created a platform (Kapi) that provides a new legal solution in the market. Kapi crosschecks the commercial partners’ information from clients with public databases in large scale and real time, identifying irregularities that could result in infractions, tax notices and other charges based on jointly responsibility. Additionally, the firm was involved in various pro bono work which clients such as Human Rights Watch, Make a Wish, Base and Instituto Devolver.

The firm recently welcomed two new senior associates: Marcela Camargo from Gaia Silva Gaede and Gabriela Grigoletto Araujo from Mattos Filho.

Client feedback

“Ownership, thinking out the box and challenging the status quo are their most strong attributes.”

“They are great on designing business models, incredible support.”

“Great availability, international.”

“Serious and personalised service.”

Founded in 2012 with offices in São Paulo and Belo Horizonte, Ayres Ribeiro Advogados specialises in tax advisory, tax controversy and indirect tax services. The expertise of the group in PIS-COFINS, IPI, and ICMS matters stand out. It is active in the agribusiness, food and beverage, automobile, pulp and paper, trade, energy and telecommunications sectors. The tax department is headed by partner Gilberto Ayres Moreira.

During the research period, the firm handled various cases related to ICMS including defending a client’s interest in a lawsuit seeking to avoid the improper collection of ICMS levied on cancelled sales. Additionally, the team defended Heineken in a tax infraction notice issued by the State Tax Authority of Bahia demanding the client pay state tax on goods and services.

Client feedback

“Proactivity, client care.”

BNS Law | Becegato, Nastromagario e Saad Advogados, formerly Correa Meyer Advogados, is a full-service law office that has been operating in the legal market for 16 years. BNS has a team dedicated to tax practice, led by the partner Marcelo Nastromagario. The office is prepared to provide services in both tax consulting and litigation areas, including judicial and administrative spheres in federal, state, and municipal levels. Among the main clients of the tax area, there are services providers, software developers, chemical industries, investment funds, real estate developers and others. 

During the research period the team represented its client in filing a writ of mandamus against the Secretary of Finance of the State of São Paulo to obtain the reactivation of the company’s state registration, which had been illegally suspended by the tax authority. The action of the firm was crucial for the client to resume its full operation.

Brigagão Duque Estrada Advogados is a new boutique firm established in 2018. It has two locations in Rio de Janeiro and São Paulo and is led by five partners, with Gustavo Brigagão and Roberto Duque Estrada being the name partners. It specialises in indirect tax and tax controversy. Its clients belong to sectors such as financial services, entertainment, oil and gas, IT, real estate, and retail.

During the research period the firm represented the Fédération Internationale de Football Association (FIFA) before the administrative courts to definitively cancel a tax assessment related to non-compliance with a regulatory rule that demanded the use of Brazilian flagged vessels” for the importation of goods benefited by tax exemptions.

Client feedback

“Attorneys Roberto Duque Estrada and Pedro Grillo, from Brigadão, Duque Estrada, have done excellent work in previous legal cases, when we work for differents clients against the Special Department of Federal Revenue of Brazil (Receita Federal).”

“They have accomplished with all stated goals and we have had the dispute winning against State Tax Inspection ,and its Infraction Notice(ICMS TAX) has been deleted!”

Briganti Advogados advises on general corporate and tax controversy matters. The team’s specialty is assisting with the reduction of tax burdens, assets recovery and avoidance of arbitrariness by the tax authorities. Leonardo Briganti is a key partner in the team.

During the search period the firm successfully represented Serveng Civilsan Empresas Associadas de Engenharia. The public authority analysed and recognized almost all the credits.

Partner Francisco Roberto Jr left the firm in November of 2022.

Client feedback

“Punctuality, confidence, accuracy, knowledge.”

The tax department at BRZ Advogados advises many different perspectives from the Brazilian taxation, both in tax consulting and tax litigation. The team assists its clients with a broad range of tax matters, such as tax and tax planning advisory, international tax, legal opinions, M&A operations, draft of administrative defenses and filing of legal actions to reduce tax burdens and recover taxes unduly paid. Renata De Paoli Gontijo and Mariana Fineberg are key and leading partners in the firm.

During the research period, the firm assisted Intelsat Brasil in filing and representing in administrative/judicial procedure. Some actions taken included studying the legislation, literature, and case law associated with the issue at hand; assessing the best strategy; drafting defense.

The firm welcomed associate Gabriel Loureiro Alves from Vieira Rezende Advogados.

Client feedback

“They are good in legal advice on all taxes, seeking solutions, and on drafting of opinions and memorandum on tax legislation.”

Bueno Tax Lawyers is known for its work with international tax matters. It provides planning and litigation to the commerce, digital and service economy sectors, as well as financial.

During the research period the firm represented Alaska Investimentos, requesting the right to exclude service tax (ISS) amount due from the social contribution (PIS/COFINS) calculation basis. The final decision from the Supreme Federal Court mayrepresent relevent tax savings

Associate José Rubens Filho left to join Freitas Leite Advogados. However, the firm welcomed new associates Talissa Koerbel from Machado Associados and Vinícius Rozenfeld from Passos e Sticca Advogados Associados. Additionally, Constanza Bodini joined as Of Counsel previously from Câmara Brasil Argentina de Comércio de São Paulo (CAMARBRA) and Interamerican Investment Bank (IDB).

Client feedback

“They have a unique balance between theoretical knowledge and practical approach. They are very tuned with the administrative and judicial case law, what allows them to foresee trends.”

“The partners have a very deep knowledge of the laws and taxes. They guided us step-by-step through legal processes and controversial matters.”

The team at Buttini Moraes has expertise in the law, accounting, and technology fields. The team assists with a variety of tax matters such as tax credit recovery, tax benefits claims, tax advisory and tax litigation. The team is knowledgeable on a variety of sectors such as agribusiness, food, retail, automotive, energy, infrastructure, perfumery and personal care, electronics, mining, machinery, and industrial equipment.

Over the research period the team was involved in various ICMS matters including a tax review and opinion for subsequent appropriation of accrued ICMS and reimbursement of ICMS.

The team welcomed associate Ligia Ferreira de Faria from Johnson and Johnson.

Client feedback

“Very specialized”

“Professionalism, speed, excellent technical knowledge, accessibility.”

“Team with a lot of technical and legal knowledge and integrated with support staff in digital tools.”

“They have great knowledge of the topic, are up to date with changes, in addition to the working partnership we have built with experts in credit monetization.”

“Has deep knowledge and generates results quickly.”

Campos Mello’s tax department consists of qualified and experienced lawyers and covers full range of tax law related matters. It provides consultancy services including advising on direct and indirect taxation, tax planning, restructuring and due diligence. It also supports litigation services and covers direct and indirect taxation at both judicial and administrative levels.

During the research period, the team represented its client’s Brazilian subsidiary in two key claims at the administrative level involving the disallowance of interest expenses for corporate income tax (IRPJ) purposes.

Senior associates, Marcelo Gustavo Silva Siqueira and Gabriel Mynssen da Fonseca Cardoso, both departed leaving to work for Kincaid | Mendes Vianna Advogados and Mattos Filho. Additionally, partner Rosana Gonzaga Jayme left for Santander Brasil. However, the team welcomed new senior associates Marina de Siqueira Carvalho from EY and Cristiane Drumond Vieira from Drumond Transfer Pricing, along with a new partner Flávia Ganzella from Felsberg.

Client feedback

“Campos Mello is an international network firm, with strong technical team and a client centric approach.”

“They provide concise and consistent tax advisory that enables the company to take business decisions in a safe and efficient manner.”

Candido Martins tax department has vast experience on tax advice and tax structures for M&A deals and in judicial/administrative procedures. The tax advisory department provides services including analysis, drafting of tax planning and tax consulting. The tax litigation department supports filing lawsuits to defend clients on undue tax requirements, advising the clients in risk assessment and revision of the client’s tax collection. Partner Alamy Candido heads the tax practice.

During the research period, the firm provided tax assistance to CSN on the acquisition of Metalgráfica Iguaçú by an incorporation of shares with the subsequent transformation of Metalgráfica Iguaçú into a wholly owned subsidiary of CSN, another company listed at the Brazilian Stock Exchange. Additionally, the team aided shareholders of Agrocat in the sale of 80% of their shares to Agrogalaxy.

Client feedback

“Knowledge and experience in several transactions with national and international companies.”

Caputo Bastos e Serra has experience in tax law matters involving advisory, government relations, tax planning and litigation in administrative and judicial proceedings. It is recognized in practice before high courts, internal and external control public bodies, Tax Authorities Courts, and the Judiciary Branch. The team consists of four partners and two non-partners.

During the research period, the firm represented Paraibuna Papeis who was facing 150 lawsuits regarding tax charges. After years discussing the liability to pay the taxes, the company reached an agreement with the tax authorities. The agreement was signed on January 2022 and reduced the debt on approximately 74 million.

Client feedback

“They are fast, well connected and understand a lot of the subject.”

Carvalho, Sica, Muszkat, Vidigal e Carneiro advises in all aspects of tax law, including tax litigation, direct and indirect tax, customs and social security taxes at the federal state and municipal levels. The firm’s tax department has a large experience working with soccer clubs and athletes.

During the research period the team advised City Football Group (“CFG”). Additionally, the team defended client Tenneco Group (Federal Mogul) in a tax dispute. That case may be relevant to any decision by the bodies of the judiciary to grant provisional judicial authorization to the taxpayer to ascertain and collect the contributions of third parties based on the application of the limit of the taxable base to the value of 20 minimum wages.

The team welcomed Livia Ricciotti as a senior associate previously from Lefosse Advogados.

André Gomes de Oliveira heads the tax team at Castro Barros Advogados. The tax team operates out of two offices in Rio de Janeiro and São Paulo, along with 30 professionals. It specialises in indirect tax, tax controversy and transactional tax, especially cross-border transactions. It maintains strong relationships with clients in the retail and telecommunications sectors.

Details of the firm’s work and clients remains confidential.

Client feedback

“Proactively informing and managing tax litigation.”

“Competent and proactive.”

“Partner office, which is not only aimed at profit, but is close to the Company, facing problems and presenting solutions. Highly qualified technical professionals.”

“Assertiveness, Ethics, Quality and Accuracy.”

“Castro Barros provides us with great support. They are knowladgeble, responsive, business oriented.”

“The firm is familiar with international legislation and dominates the technical knowledge about tbu - taxation on universal bases like few others.”

Founded in 2020, CBLM Advogados is a law firm specialised in tax law. It focuses on tax services including assistance in tax inspection procedures, administrative and judicial litigation, tax consulting, special regimes and rulings, and wealth planning.

During the research period, the firm advised Siemens-Gamesa on relevant transactions and tax assessments. This included local operations as well as international. Many deals with Siemens-Gamesa revolve around key tax controversies for the wind power industry in Brazil which have the potential to create new guidelines for the entire sector.

Partner Marcelo Rocha departed March 2022. However, the firm welcomed a new partner, Luiz Carlos Junqueira Franco Filho from Franco Yoshiyasu Maia Simões & D`Alessio Advogados (FYMSA).

Client feedback

“They are very consistant and straight to the point.”

A well-regarded firm in Brazil, Cescon Barrieu Flesch & Barreto Advogados stands out with its strong transactional tax practice, reputation for sophisticated tax structures, and corporate structuring acumen. The firm’s expertise is particularly strong in the pharmaceutical, energy, and consumer goods industries.

During the research period, the team represented Via Varejo in a dispute involving the deduction of goodwill-related expenses. This was a relevant precedent not only to the client but also to all taxpayers, since it is was one of the first favorable precents of the CSRF involving the amortization of goodwill in this kind of tax planning

The team welcomed Carolina Romanini Miguel from Machado Associados as a partner.

Client feedback

“Technical knowledge and responsive.”

CGM’s tax team comprises professionals with more than 25 years of experience in the area. It specializes in direct taxes (including transfer pricing), indirect taxes, tax litigation and international taxation. The firm represents clients mainly in the automotive, pharmaceutical, technology, entertainment, services, and luxury markets.

During the research period the team represented its client in recovering PIS and COFINS tax credits. The group obtained several favorable decisions granting a very expressive number of credits.

Senior Associate Cecília Yokoyama departed the firm to Machado Associados. The firm, however, recruited partner Ricardo Marletti Debatin da Silveira, previously from Machado Associados, in addition to senior associate Ricardo Valim de Camargo from Farroco Abreu Advogados.

Client feedback

“Quality of work and expertise in the field of partners: Angelica Santos e Ricardo Silveira.”

“They go deep on the research that are doing”

“Fast response and Great knowledge about the Brazilian tax rules.”

Claudio Zalaf Advogados Associados (CZAA) was founded almost 60 years ago and has established itself as a leading firm not only in Campinas/SP and its surroundings, but also in the whole State of São Paulo. With offices in the cities of Campinas and Limeira, clients are from a broad range of economic sectors, mostly notably industries, trade companies, and service providers. In relation to the tax practice, it assists clients in advisory and litigation matters, representing clients before all instances of judicial and administrative courts around the country.

During the research period the firm represented client, Elring Klinger do Brasil, given that the good faith and credibility of the company has been placed in doubt by the Treasury Department. The team recovered a judgment to declare the good standing and good faith of the client in a commercial transaction carried out with a supplier declared disreputable by the State Treasury Department of São Paulo, years after completing the transaction, in relation to which the tax authorities drew up, at that time, a Notice of Tax Deficiency and Imposition of Fine (AIIM).

Client feedback

“Technical Knowledge, assertive analysis of jurisprudence, CRM.”

“Very Reliable, quick and flexible”

CMARTINS’ tax team specialises in tax planning, advice and litigation. It is experienced in dealing mainly with clients from industry sectors such as telecom, IT, textile, foods and beverages, aviation, pharma, healthcare, consumer goods, energy, and infrastructure, automotive and financial.

During the research period the team the team advised Hamilton Beach Brands do Brasil Comércio de Produtos Elétricos in recovering over BRL 2,000,000.00 of receivable credits related to State Taxes levied on the sales of products in Brazil (VAT). Additionally, the team advised Associação Brasileira dos Fabricantes de Brinquedos in transfer pricing matters. This case was an opportunity to deal with OECD guidelines and their application for Brazilian transactions.

Coelho & Dalle Advogados was founded in 2007 and recently expanded its services to international companies. It offers support to foreigners with business in Brazil in various languages including English, Spanish, Italian, French, and German. The tax practice covers both litigation and advisory complex and strategic matters, including advisory services for litigation prevention, tax assets and liabilities analysis, review of procedures, tax planning and due diligences.

During the research period the team represented and defended its client, Bradesco Leasing, in a lawsuit regarding a municipal tax (ISS), in which the Municipality of Goiânia/GO requires the payment of the tax for leasing transactions.

The team welcomed Letícia Gibson as an associate in the tax department. Previously, she worked with the firm’s litigation department.

Client feedback

“They are uptodate regarding the changes in the tax laws and are commited to know the company and our business.”

“They have absolute dominance of the subjects, and they always have a smart and fast answer.”

Founded in 2011, Coimbra & Chaves Sociedade de Advogados specialises in business and labour law, with a strong reputation in tax law. Founding partner Paulo Roberto Coimbra Silva heads, the tax team at the firm, which also operates in Brasília in addition to its main office in Belo Horizonte. In late 2018, the firm opened its newest office in São Paulo. It focuses on clients in the automobile, mining, steel, energy, and natural gas sectors. The team specialises in tax controversy.

During the research period, the team was contracted to represent represent Stola in a strategical process (in terms of financial and judicial relevance) discussing the Supreme Court interpretation about an additional tax charge under the payroll due to labor environment risks (ADRAT). The case resulting in expressive economic value for the company and increased its competitiveness in the market.

The tax team at Crespo Gregio Advogados advises on tax litigation matters, as well as general corporate tax and tax due diligence. The firm is focused on business law and assists large clients in all industries.

During the research period, the team advised Companhia de Transmissão de Energia Elétrica Paulista in filing a Writ of Mandamus to obtain a certificate of tax regularity standing for all the company's properties.

Client feedback

“Deep knowlodge and good value for money.”

“The have a full experience in taxes and great value for money.”

Cruz Campos Lobo Advogados acts nationally with a strong presence in Brazil’s Northeast area, where it assists large and medium-sized companies in general corporate tax and litigation matters. The team is composed by six lawyers, and it is led by Leonardo Nuñez Campos. Among its clients are companies acting on renewable energy, oil and gas, fuels distributors and gas stations, mining industry, transportation, retail, construction, call centers, as well as manufacturers and operators in the wind power market.

During the research period, the firm took over the sponsorship (there was more than 200 law offices working for them) of all civil and tax disputes of Brazil’s North and Northeast regions, which involves a liability of approximately BRL 2.5 billion on tax area and civil suits which involves around BRL 1.5 billion in credit recoveries cases, detinue claiming, and defense in lawsuits.

The team promoted Bernardo Sanjuan Borges.

Client feedback

“They are very specialist and seek to understand the client's business in order to make the work targeted and highly qualified.”

“Great team. Technical, fast, committed, organized.”

Da Fonte Advogados has provided specialized legal advice in tax law since 2000, when it was founded. Offices are in Recife, São Paulo, Salvador, Brasília and now also Fortaleza which opened in 2022. The team has a strong litigation practice in court and administrative proceedings throughout the country and work in due diligence and advising clients during tax inspections. Clients are key players in the following sectors: industry, health, logistics, technology, civil construction, retail, and energy.

During the research period, the firm represented Sao Braz who filed a lawsuit against the National Treasury to obtain recognition of the unconstitutionality of the requirement of an isolated fine, for failure to collect estimates, concomitant with the ex-officio fine, for lack of payment of IRPJ/CSLL ascertained in the annual adjustment.

Client feedback

“Expertise, Ethics, Commitment. They have a multidisciplinary team, which helps when providing support.”

Daniel & Diniz Advocacia Tributária is a tax and customs law boutique of three partners and two associated lawyers. Carlos Daniel and Diego Diniz are key partners at the firm. Daniel and Diniz have extensive experience in CARF. The third partner (Antônio Atulim) is a former tax auditor from the IRS, who worked as a Tax Judge at CARF for 13 years and joined the firm to strengthen both litigation and consultancy expertise.

During the research period, the team advised Grupo Lojas Americanas related to a custom fine and tax charges (tax on industrialized products) based on occurrence of fraudulent filing of third parties in import operations. The case covered customs litigation on a high level of complexity because multiple cases were being handled simultaneously with different chambers and different judges. The case is ongoing.

The team welcomed Eric Imbimbo as an associate lawyer previously from Dias de Souza Advocacia.

Client feedback

“Carlos Daniel is the lead partner of the firm. He is a former judge from the administrative tax court (CARF), with a lot of experience in corporate income tax matters. He lieases an accademic background with a practical approach.”

“They're small, but with a great expertise on the administrative tax jurisdiction.”

“The profissional services rendered by this law firm require sophisticated technical expertise, which Carlos Daniel, who is a partner at Daniel & Diniz, has. Carlos Daniel has a rare combination of accademic background, years of practice and accounting knowledge.”

“Good knowledge and proximity of partners to customers.”

“Creativity combined with above average knowledge of the latest administrative court precedents.”

“Very business oriented with a comprehensive analysis what could be the operational impacts and the possible trade-off to the best compliance level.”

“Search for a customized solution for the case, demonstrating above average knowledge of tax legislation.”

“Available partners, high technical knowledge, good price and payment terms.”

“The firm brings the experience acquired while they were judges at the federal administrative tax court.”

“Very profound and timely.”

The tax team at Deccache Advogados represents its clients in administrative and judicial proceedings seeking the recovery of tax credits or the annulment of federal, state, or municipal taxes, in the most varied Courts in Brazil, including in the Administrative Council of Tax Appeals, Court of Taxes and Fees of the State of São Paulo and Superior Courts.

During the research period, the team represented Tetra Technologies do Brasil in a lawsuit to cancel tax notices. It developed a multidisciplinary legal and technical study that shows that only approximately 10% of the value fined remains in the tax notice.

Client feedback

“They are excellent in the formulation of all the strategies and also on the contentious if necessary.”

“They have great commitment to the customer, study a lot and are very accessible.”

The tax department at Deloitte Brazil is led by Luiz Fernando Rezende. It offers a full range of tax law services but specialises in general corporate tax, transfer pricing and indirect tax. It maintains strong relationships with its clients from all around the globe, many of which are multinational groups.

During the research period the firm advised one of the largest multi-brand restaurant operators in Brazil and Latin American. In doing so, the team was able to utilize a new proprietary Deloitte Brazil technology solution (so called D.gger) to seek for VAT opportunities. The use of technology was essential to reduce project timing completion as well as well as to identify VAT issues that would be extremely burdensome if performed manually.

The team recruited two partners: Rafael Maciel da Costa Oliveira from Avalara and Carlos Eduardo Eliziario de Lima from Dannemann Siemsen. Additionally, two directors: Marcelo Santana Rezende from EY and Philip Robert Lejuene from Kelly Services.

Client feedback

“Commitment and expertise.”

Spanning four offices in Brazil and one in New York, Demarest Advogados focuses on the practice areas of tax controversy, indirect tax, and transactional tax, specifically M&A and cross-border transactions. Its tax department consists of ten partners who lead five counsel and 45 lawyers. Its clients are from a diverse set of sectors including automotive, pharmaceutical, industrial manufacturing, agribusiness, life sciences and F&B.

During the research period the firm advised Alvarez & Marsal in all tax issues related to the structure and registration of the first Brazilian Special Purpose Acquisition Company (SPAC) listed as a public company by the Brazilian Securities and Exchange Commission (CVM). The pioneering deal will allow the entry of a new investment product in Brazil, which should contribute to the further development of the country’s capital market. The tax structure is innovative given that it would allow the foreign investment in the SPAC with the Brazilian income tax benefits related to a portfolio investment (Resolution 4,373). This specific tax benefit granted the income return desired by the foreign investors to have a SPAC structure in Brazil.

Partner Antonio Carlos Gonçalves left the firm in February 2022, however, the firm recruited three new partners Angela Cignachi, from an independent practitioner, and Roberto Casarini and André Novaski who were promoted.

Client feedback

“High efficiency”

“dedicated”

“They are very commited with the deadlines and provide a very complete analysis of all jobs they perform to us.”

“Always bring a very techinical analsys and explain very well their view on each case”

“Without any prior partnership, the attitude of Demarest tax team was outstanding, in terms of availability to listen to our story to quickly explore possibilities and present them in a very comprehensive and clear way to the global leadership, even with a very short notice. The quality of the end result was outstanding.”

“Excellent approach on understanding the business and exploring alternatives, discussing impacts and reaching an outstanding quality legal opinion shared with senior management of the group.”

“Demarest's litigation team (in both spheres: judicial and administrative) have partners (such as Priscila Faricelli and Gisela Crivellaro) and associates (such as Marco Favini) with notadable knowledge and who provide us a high-quality service.  We have also interacted with the partner Christiano Chagas and the associate Dora Pimentel with other transactional matters (such as tax-implications in M&A transactions), who also surprised us with the quality of the service.”

“Demarest law firm is able to provide full service, and its tax team is highly technical. The attorneys investigate deeply the issues and bring solutions with excellence. Their deliverables are deep and always customized to the customer needs.”

“This Law Office has recognized good service and background to treat the most complex themes related to tax matters, having a good portfolio of clients which permits to deal with various cases and their solutions.”

“He has in-depth knowledge in the tax area, especially in matters related to M&A and his professionals have a great sense of urgency that speeds up decision-making.”

Founded in 2002, the tax team at Dias Carneiro specializes in indirect tax, transactional tax, and most notably, customs. Its clients vary in sector, but include pulp, forestation, and reforestation, pharmaceutical, technology, machinery, sugar and biofuels, insurance, telecommunications, and real estate. The tax department is led by Antonio Amendola.

During the research period the firm aided and represented Rio Bravo against a series of Notice of Infraction. Other details of cases and clients are confidential.

Renan Castro left the firm in November of 2022. However, the team welcomed five new associates: Julie Maciel Rozani from Machado Nunes, Lucas Barcellos from Rivitti e Dias Advogados, Ana Paula Chaves from Machado Meyer Sendacz Opice Advogados, Samantha Peloso from Mercado Bitcoin, and Júlia Figueiredo Laviola from Santos Neto Advogados.

Client feedback

“Full service firm with tailor made approach. 3 great tax partners.”

“Proactive, assertive in their advisory and diligent. They support several tax discussion in our operation and already bring relevant victories representing more than USD 2M.”

“The team offers us confidence in the legal foundation and in the actual tax calculations, as well as security and smoothness in the procedures with the government departments.”

“Rodrigo Maito and his team demonstrate strong technical skills on Brazilian tax matters (particularly realted to real estate topics) and were extremly avalilable to long discussions on structuring alternatives. Specifically, Rodrigo Maito combines a solid technical and academic basis with a desirable business driven view.”

“The office has a robust structure to attend to tax demands, with nationally recognized lawyers. In relation to the Rio Bravo case, Mauricio is always available to assist with any demand and closely monitors the process.”

The firm at Dias de Souza Advogados Associados is renonowned in its area of expertise, tax law. In the field of litigation, it is known for its outstanding work in judicial and administrative courts. In the field of consulting, the team is known for analyzing issues regarding Public Law, with counseling, legal opinions and reports on preventive practices, definition of strategies for actions in progress and tax planning, with focused and thorough risk assessment, which produces outstanding results, due to its solid and innovative method. The firm also works to improve legislation on issues that affect the market, including drafts for amendments to the Federal Constitution.

During the research period, the firm represented various confidential clients at the judicial and administrative spheres.

Diego Joaquim & Advogados (DJA) is a boutique firm located in Campinas/SP, focused on customs, international trade and all the tax and compliance related to both. Putting into practice the customs policies and laws defined by the countries involved, we act in various spheres, from defense in relation to seized cargo to the prevention and audit of customs fines. The location in Campinas is strategic in such sense, as closely to the main airports of São Paulo State (Viracopos and Guarulhos), and close to Santos where the largest Latin America port is located.

During the research period, the firm was involved in various customs cases including providing advisory to Nuno Fracht Integrador Logístico on management of a Global Trade Compliance Program for Customs activities according to the legislation in Brazil, including checking procedures, evidence, managing risks, and comply with legal requirements. Efforts of the team allows the client to improve operations and ensure compliance with the legislation.

Client feedback

“All the team involved with the provided advisory service showed extensive knowledge on customs and environmental legislation.”

“Technically skilled, client-oriented, very good understanding of the network in Customs in Brazil. Outstanding attitude and a very pro active way of performing his role as counsel.”

“They have a competent teamwork and comprehensive experience on this job.”

“Extensive knowledge in the customs area and current legislation.”

“Deep Knowledge on Brazilian Harmonized Codes system and Customs Regulation, as well as Chemistry Expert supporting the Legal side with technical inputs. Well balanced in terms of Knowledge, Strategy and Execution.”

Duarte Garcia Serra Netto & Terra Advogadoss practice consists of assistance on tax and corporate law issues domestic and foreign companies in various economic sectors, assistance in structuring and restructuring business operations and tax planning mechanisms, assessment on transactions in the financial and capital markets, including the structuring of investment funds and assessment on mergers and acquisitions operations. The work of this practice also includes tax litigation, preventive assistance and advisory as to taxes concerning industrial, commercial, and service activities. The firm particularly stands out for its record of tax disputes that affect a large variety of clients playing important roles in the real estate and service sector, because of its intense practice in both administrative and judicial Courts.

Details of cases and clients are to remain confidential.

Client feedback

“Local expertise with global knowledge of business associated with profound technical foundation.”

“In-depth knowledge of tax matters and organization.”

Eduardo Menna Barreto provides legal services to national/international companies and investors and geared towards business structuring, mergers, and acquisitions. It is highly specialized in various areas of practice, having expertise and advanced knowledge in complementary areas such as accounting, finance, and negotiations. The team consists of two partners and two non-partners.

During the research period, the firm advised Costa Hirota in the elaboration of lawsuits to discuss the illegality of the linkage between the Occupancy Permit’s issuance and the payment of a tax called “ISS Habite-se.” This matter is very relevant to the building sector because it is the final step to obtain the Occupancy Permit and the municipalities take advantage of it to bind a high and artificial tax.

The firm welcomed senior associate Rafael Pascoto Fugimoto, previously from FH Law.

Client feedback

“Proactivity, analyse the big picture and sense of urgency.”

Founded in 1951, Ernesto Borges Advogados’ tax team specialises in tax controversy and indirect tax. Its clients come from sectors such as pulp and paper, manufacturing, tobacco, textiles, and energy. The firm operates across three offices. Partner Flávia Andrea Sant´Anna Ferreira Benites is the main litigation practitioner.                                                            

Details of the firm’s work and clients remains confidential.

Client feedback

“Deep knowledge on tax matters. Close contact with the client.”

The practice at Farroco Abreu Guarnieri Zotelli Advogados is a full-service firm with distinction in general corporate, M&A, wealth management, and tax. Complementary service lines are employment, litigation, and regulatory law. The team includes 22 professionals that operate from São Paulo. Partner José Mauricio Abreu co-heads the team with repute in litigation.

During the research period, the firm assisted Associação Brasileira de Empresas de Tecnologia da Informação e Comunicação (BRASSCOM) in a class action on the constitutionality of tax on technology transactions. The main work comprised demonstrating that collecting ICMS on digital commodities constituted double taxation and was thus unconstitutional.

The team welcomed Luiza Martinelli Menezes, previously from Moraes Jr Advogados.

Client feedback

“Farroco Abreu is a boutique firm with a top notch team, and highly technical partners with extensive background and amazing track record.”

“They are very specialized, comptent, diligent, and reliable.”

FAS Advogados has a market reputation for its flexible business model to cater seamlessly to differentiated sectors on the domestic and international market. Counsel is given to a broad industry spectrum across technology, payments, retail, and advertising. Corporate reorganisations, equity governance and judicial litigation are attributes. Partners Leo Lopes de Oliveira Neto and Rafaela Lora Franceschetto are key practitioners.

Details of the firm’s work and clients remains confidential.

The firm welcomed Bárbara Almeida Correa as a tax litigation manager previously from ASBZ Advogados.

Client feedback

“Always updated about legislation, doctrine and jurisprudence to be used and big knowledge over the main aspects to be considered in Brazilian Environment.”

The tax department at Feijó Lopes Advogados is best known for providing strategic advising to Technology, Banking, Manufacturing, Retail, and Agribusiness companies on matters related to investments, M&As, and new products. The department is also recognized as a leading litigator in active and passive cases involving federal, states and municipality tax on corporations.

During the research period, the firm assisted Sicredi and Cooperatives in several matters regarding tax issues of their operation. Mainly tax regarding Social Security contributions on gross income (PIS and COFINS), Withholding tax on remittance abroad (IRRF in Portuguese), Tax on financial operations (IOF in Portuguese), Social Security contribution on net income (CSLL), Corporate tax (IRPJ), etc. In addition,the team advised in a matter regarding international taxation.

Partner Maurício Luís Maioli departed the firm, however, two new partners were welcomed from Martinelli Advogados: Christian Lisboa Rodrigues and Gabriela Vieira da Costa.

Felsberg’s Tax lawyers are multidisciplinary with backgrounds in business administration, accounting, and audit training. It has an international profile, supporting foreign clients in setting-up, carrying out, expanding or winding-up their activities in Brazil, in a tax-efficient way. This involves complex and practical tax and customs consulting to all industries, cross-border as well as domestic investments and types of business transactions in Brazil. The tax litigation team handles cases involving amounts totalling over BRL 1 billion, establishing efficient and results-oriented strategies. It acts in both administrative and judicial spheres.

During the research period, the firm advised on debt reprofiling and judicial reorganization plan for Paranapanema. This included tax advice on debt reprofiling, including the renegotiation of a tax-incentivized export pre-payment facility. Tax advice on the design of the company’s judicial reorganization plan.

Client feedback

“Great with the client, very ‘human’, smart.”

“Always helpfull, available, great at their job.”

“They are very close to us, human, great at their job.”

“Very experienced team, they meet the deadlines they promise and are proactive in all matters. Cordial and always willing to serve the client.”

“They are very good advisors, and have great knowledge of the tax area.”

“Great availability and capacity to provide the right update with the right level of detail which is quite a challenge given the complexity of the procedures in Brazil. Very reactive as they monitor closely all the procedures and proactive, in proposing new angles / ideas to challenge the tax adminsitration. All in all a great support in a very challenging environment.”

“Excellent technical knowledge, Great Expertise, Excellent disposition and quick attention. Great English level which is very important for our group.”

“Felsberg Advogados has an excellent level of knowledge of the area and provides an excellent level of advice.”

“A multidisciplinary vision is one of Felsberg's strengths, as the Brazilian tax environment is extremely complex.”

"Very professional, operative & flexible, Quick (in time support)& high quality value of provided services for acceptable service prices. Very supportive & pro-active.”

Ferraz de Camargo & Matsunaga works in partnership with law firms in more than 160 countries. The team advises on a variety of tax matters such as tax planning and structuring, tax controversy and M&A transactions. The team represents its clients in both administrative and judicial procedures. The firm works with different sectors such as automotive, agribusiness and financial and technology sectors.

During the research period, the firm represented various clients such as KPMG Brazil Group in the judicial defence of multiple cases related to the same matter but also coordinating the presentation of the court financial guarantees for the tax liabilities and obtaining the tax clearance certificates. Additionally, FCAM represented ISA CTEEP to defend the company´s right of deducting in the Corporate Income Tax basis calculation the amount of the Interest on Net Equity paid to its shareholders related to positive results from previous years.

Client feedback

“Professionalism and knowledge.”

“The Knowledge of our business and in the tax area.”

“They have an objective way of writing, without loosing the focus in what is really matters.”

“Very responsive, aiming to understand our needs to improve the quality of the outcome.”

The FIUS tax practice is specialised in international taxation, tax planning and litigation services in association with accountants and trade specialists. Based in Campinas the firm is trusted counsel for prestigious multinationals with operations in São Paulo. Partner Bruno Marques Santo is complemented by five senior practitioners.

Details of the firm’s work and clients remains confidential.

Coordinator, Rodrigo Ferreira, left the firm for KMPG during the research period. However, the firm welcomed a customs litigation lead, Rebeca Ayres, previously from Timmermans Advogados, and an indirect tax senior associate, Hozana Lima, previously from PwC in the same space.

Eduardo Fleury heads the tax department at Fleury Coimbra & Rhomberg Advogados. The team is active in tax consulting, tax controversy and transactional tax, specifically in cross-border transactions. Its strengths lie in the industrial and manufacturing, IT, oil and gas, clean energy, and healthcare sectors. It works with multinational firms and maintain strong relationships with international clients.

During the research period, the firm assisted Smurfit Kappa on filing a lawsuit to challenge the undue limitation of the tax credit of REINTEGRA before 90 days of the new law which reduced its benefit. After a favorable precedent in the lower court, the team is waiting for the final decision to recover the undue limitation of the tax credit over 90 days after the new law which reduced its tax benefit.

Partner Lucas Lobo departed to Carvalho Magalhães in April of 2022.

Fonseca Moreti Advogados is a law firm that can perform a wide range of services as: Tax Advisory and Planning for all sectors of economic activities, Elaboration of projects aimed at obtaining Special Regimes and Tax Incentives, Due Diligence for the incorporation, merger, acquisition and spin-off of companies, Monitoring and legal management of corporate tax liabilities, and Presentation of defenses and appeals in administrative tax proceedings before Administrative Councils and Courts within the scope of the Union, States and Municipalities.

During the research period, the firm represented Webfones Comércio de Artigos de Telefonia. The case consists in the recognition of the right not to include, in the calculation of the Cofins and Contribution to PIS bases, the amounts corresponding to these own contributions, as well as to offset the PIS and Cofins credits ascertained in the last five years due to the cleavage of the aforementioned contributions from their own calculation base, duly updated by SELIC - art. 39 of Law no. 9,250/1995, with the credits of any federal taxes, in the form of the law.

Founded in 1993, Fraga Bekierman & Cristiano Advogados is active in tax controversy and general corporate tax. Its clients are in sectors such as oil and gas, pharmaceutical, energy, shipping, chemical, food and beverage, telecommunications, technology, and financial services.

This past year the team assisted FKB Equipamentos with tax and corporate matters. Additionally, the firm represented Sociedade Michelin de Participações, Indústria e Comércio in adminsitrative proceedings, fuled to challenge and import taxes charges due to divergence in the fiscal classification of goods.

Three associates departed during 2022 including Leonidas Barbosa Quaresma Neto, Bryan Machado Acioli Lins, and Marcos Antonio da Silva Olinto.

Client feedback

“They work in several areas, and for the services we use, they have a good knowledge of the tax and corporate aspects.”

Freitas e Vieira Advogados is a boutique firm founded in 2017 with a focus on tax law. Led by Rodrigo de Freitas and Rodrigo Rodrigues Leite Vieira, the group brings a broad and innovative set of knowledge to a broad spectrum of tax issues. The group has done significant work in finance, industry, services, and healthcare.

The last year, the firm represented Banco BESA and filed an action challenging the charge of the Brazilian social contribution on net income (CSLL). It was demonstrated that the Bank had correctly paid and declared the amounts due as a social contribution, since it was a spontaneous reporting of the debt to the tax authorities.

The firm welcomed Rodrigo Nogueira de Souza as senior associate, previously from Thielmann & Nogueira Advogados.

Client feedback

“Highly skilled and qualified. Great customer service and business savvy.”

Gaia Silva Gaede Advogados has five offices throughout Brazil, in São Paulo, Rio de Janeiro, Curitiba, Belo Horizonte, and Brasília. The firm is made up of 19 partners and about 200 lawyers. It has a strong presence in various sectors such as technology and innovation, ecommerce, healthcare, oil and gas, consumer goods, pharmaceutical, insurance, agribusiness, automobile, construction, energy, and financial services. It is active in the practice areas of general corporate tax and tax controversy.

Over the past year the team filed a lawsuit on behalf of Furnas – Centrais Eletricas to cancel the tax assessment issued to charge Corporate Income Tax (“IRPJ”) and Social Contribution on Net profits (“CSLL”), plus fines related to the exclusion, from the basis of calculation of such taxes, of the revenue arose from the reversal of an actuarial liability maintained with the Fundação Real Grandeza. The office obtained a favorable judgement for the client.

The team welcomed two new senior associates: Cassiano Bernini from B2CR Sociedade de Advogados and Daniel Gelcer who was promoted.

Client feedback

“Knowledge about tax planning and O&G industry, Communication with customer.”

“They are providing a near work to the client, avaiable, ethic and high level technicaland innovative”

“They are winning several cases and providing good results in terms of cash and P&L to the company, bringing good and news ideas to implement.”

“GSGA is well talented and pro-business, with an excellent cost-benefit.”

“Experience, knowledge, availability and engagement.”

“They know a lot about the business which is a great thing, also, they are very responsive.”

Galvão Villani Navarro Zangiácomo Bardella Advogados was founded in 2020 and assists entrepreneurs, high-income families, and individuals in various tax, legal, and inheritance demands related to their businesses and/or assets, in Brazil and abroad, as well as legal departments, family offices, managers, start-ups, investment funds, with a focus on tax and customs consultancy and litigation. The firm is highly specialized in Private Wealth and Family Offices. Other services include, but are not limited to, direct taxes, indirect taxes, international taxation, and tax litigation.

During the research period the firm assisted Savoy Indústria De Cosméticos with the Administrative Defense Review. Assiatsnace was necessary given an accusation of simulation in the interposition of wholesale commercial between industry and retail with the sole purpose of saving PIS and COFINS. Discussion about the limits of tax planning, anti-elusive rules, abuse of form and right, and fraud. 

The firm welcomed partner Marcia Harue, previously from Hallem Advogados.

Client feedback

“Carlos Navarro is a naming partner of this firm and he is a very skilled lawyer”

“I have worked in Machado Associados for several years with the founding partners Tatiana Villani and Carlos Eduardo Navarro, who are outstanding tax lawyers, very well prepared and client focused. Although this firm has been founded few years ago, I consider it to be an excellent tax boutique.”

“Extremely knowledgeable on Brazilian and UK tax lawsas well as insights of possible short term changes. Long term knowledge of company's structure and business.”

“1. Expertise - Know-how 2. Flexible agenda 3. Hands-on and open to support the clients”

“They are very diligent and knowledgeable, providing very good services to their clients.”

Gasparini, Nogueira de Lima e Barbosa Advogados has a team of four lawyers specialized in assisting companies and individuals in all matters related to tax law, both in the advisory area and in judicial and administrative litigation. The practice is geared towards contentions tax matters, and the team has extensive experience helping clients challenge tax collection actions, from income tax, social contributions, ICMS, ISS, etc. The firm advises some wealthy Brazilian families on estate planning and succession issues involving large rural properties, real estate, and equity investments and clients in several import/export issues, as well as on benefits associated with free trade zones.

During the research period, the firm assisted Enel in a lawsuit before the Federal Curt to offer a guarantee for fiscal regularity considering the emergence of executable tax debt and the client’s urgency to obtain the certificate of good standing (CND) necessary to participate in a large public bidding process. Without the certificate, the client would lose out on the bid, which would have a direct impact on the company's profitability.

Partner Daniel Miotto left the firm February of 2023.

For 30 years, Gomes & Hoffmann, Bellucci, Piva Advogados has been operating in the Brazilian legal market. The tax team has a solid performance and understands the current Brazilian challenges in its complex legislation and inspection system. The main services are Administrative and Judicial Tax Litigation, Strategic and Routine Tax Consulting for all taxes and participation in tax operations of great national importance.

During the research period, a client approached GHBP Advogados to assess the possibility of reducing the amount to be paid as property transfer tax. Analyzing the operation, GHBP filed a Writ of Mandamus seeking an injunction so that the aforementioned tax would not be collected on the amount set by the Municipality of Campinas, but on the value of the operation. The preliminary injunction was granted, which enabled the customer to pay the reduced tax. After the procedural steps, the Judgment was published confirming the preliminary decision obtained by the company.

The firm is known for sector agnostic distinction in tax litigation on the Brazilian market. Representations are routinely sought from the hospitality, construction, engineering, and technology industries. Cross-border transactions are an additional complement for the world’s leading multinationals. Partner Rodrigo Gomes Cardim de Gil is a key practitioner contact.

Some highlights from the past year include assisting Grupo Veneza with several lawsuits challenging the validity of the collection of ICMS-DIFAL tax in the year 2022. Additionally, the firm assisted LBR Engenharia e Consultoria with a tax enforcement action claiming the levying of Tax on Services (ISS) on engineering services rendered by the company to public agencies in several municipalities since the Municipality of São Paulo requires that the collection be carried out in its territory. 

The department at Guimarães & Vieira de Mello Advogados has a strong presence in judicial and administrative tax litigation, with high performance in Administrative Council of Tax Appeals – CARF. Clients work in a wide range of areas, such as finance, mining, engineering, hospitality, sports games, industry, services. In addition, the team works on tax planning for high-income individuals and companies in general.

Details of the case and clients are to remain confidential.

Client feedback

“Objectivity, technical competence, agility and security.”

Guilherme de Almeida Henriques is the founding partner at Henriques Sociedade de Advogados. It operates in the practice areas of indirect tax, tax controversy and general corporate tax. Its clients are active in sectors such as the construction and financial services. Founding partner Guilherme de Almeida Henriques is ably assisted by Marcelo Hugo de Oliveira Campos.

During the research cycle, the team represented Gramado Parks Investimentos e Intermediações in a lawsuit regarding a tax benefits program (PERSE) that aimed to reduce the tax rate of federal taxes to 0%, because of the financial losses that companies had due to the COVID19 pandemic. The case resulted in the optimization of the client’s financial result. The mandatory injunction was one of the first court’s decision in the country.

Client feedback

“Proactive and competent.”

The tax practice at Hilú, Costódio & Caron Baptista Advogados has an auspicious reputation for consultancy in tax and customs matters, tax planning and judicial litigation. Sectoral coverage encompasses technology, real estate, pharmaceuticals, and energy.

Details of the firm’s work and clients remains confidential.

Client feedback

“Clear and objective answers that are easy to understand given the complexity of the subject in the country.”

The tax team at HRSA is frequently sought after to advice on M&A and Private Equity transactions, with tax planning remaining a strong area for the firm. The work on corporate reorganization and tax planning for companies is a significant and well recognized practice of the team. The tax litigation team benefits from the team’s experience in handling direct and indirect taxes in corporate transactions.

During the research period, the team represented GA Yustrich Participações by presenting administrative defense against the tax assessments and is discussing with the client and the class association the strategy to overrule São Paulo’s initiative on taxing Self Storage’s activity. The client is a major player in Self Storage business in Brazil and the matter impacts the activity as a hole.

Spanning across two offices in São Paulo and Brasília, Huck Otranto Camargo Advogados was established in 1993 and specialises in transfer pricing, tax controversy, indirect tax, and transactional tax, specifically cross-border transactions. The team has expertise in multiple practice areas spanning tax law. It works with clients from various sectors such as pharmaceuticals, insurance, education, plastics and food and beverage.

During the past year the team, the firm assisted Saint-Gobain in an Administrative Tax Litigation related to the formal restrictions imposed by the Brazilian Tax authorities to ensure the recognition of the tax paid by a company controlled abroad. The success of its performance may result in the relaxation of the evidentiary requirements for offsetting tax paid abroad by all companies headquartered in Brazil, which receive profits abroad.

Several partners departed to HRSA including Mauricio de Carvalho Silveira Bueno, João Paulo de Seixas Maia Krepel, Isabel Garcia Calich da Fonseca, Lucas Martini de Aguiar, and Ana Flora Vaz Lobato Diaz. However, the firm welcomed partner Marcelo Muratori previously from Mariz de Oliveira e Siqueira Campos Advogados and promoted Vitor Fernandes Chaves.

i2a Advogados tax practice advises international and Brazilian clients on all aspects of tax planning strategy. The team has substantial experience addressing tax issues that arise in M&A transactions, as well as taxes that affect capital markets, financial institutions, and insurance and reinsurance providers. It advises companies from a wide range of industry sectors, with special focus on banking and finance, investment funds, real estate, and timberland.

Details of the firm’s work and clients remains confidential.

Client feedback

“Focused and experienced team.”

Established over 15 years ago and headquartered in Porto Alegre, ILARRAZ Advogados advises its clients in general corporate tax and tax controversy matters. The team of 15 practitioners advises clients from a broad range of sectors such as environmental, administrative, contractual and digital law, to cite a few. Marcelo Ilarraz leads the firm’s tax team.

Details of the firm’s work and clients remains confidential.

Client feedback

“Very good understending and updated about brazilian taxes.”

“Ilarraz Advogados has an excellent level of efficiency in service, follow-up and development of action strategies for the different situations of our company.”

“Ilarraz has professionals with extensive experience on the ground in Brazil combined with a strong international tax background and multilingual skills. Ilarraz has access to a unique international network which very few competitors could match in the local market.”

“Actions and advices strongly based on brazilian legislation.”

The firm was founded in 1983 with thematic focus in administrative law relating to state-owned company legislation. Litigation services in the judicial sphere covers singular entities and multinationals. Advisory services include tax planning and HNWI counsel to esteemed international clients. Partner Cinthia Benvenuto is the main practitioner for restructuring advice, alongside senior lawyer Thiago Decoló Bressan for litigation.

A highlight during the research cycle was the tax benefit the team was granted from the government for Grupo CS Brasil. If the claims are granted, the companies will be able to use the tax benefit for a period of ten years, which will result in extremely relevant economic success.

Junqueira Ie Advogados was formed in 2019 by experienced tax professionals. The firm provides specialised services related tax, corporate law and governance and family law. It also has experience in regulatory advice and foreign mutual funds, institutional investors, and foreign exchange regulation. Partner Lavinia Junqueira and Cristiane Ie are key practice practitioner.

Details of the firm’s work and clients remains confidential.

Two associates, Alina Miyake and Diego Peñas left for Lefosse Advogados and Nabarro & Pfeferman Advogados respectively. However, the team welcomed two new associates, Marina Pettinelli from Barbosa, Müssnich Aragão Advogados, and Tais Paschoalino previously from Eduardo Menna Barreto Sociedade de Advogados.

Client feedback

“Lavinia is an expert in this field, very updated and with a practical approach.”

Client feedback

“Proactive and open to negotiate fees. Very professional and very good knowledge.”

“They have good and clear communication with the Authorities, strong knowledge of the legislation and, the differential attribute, is that they understand the business itself and how the Company operates.”

“KLA works very close to the customer.”

“They are very reliable and have excellent technical knowledge.”

“A great attribute of KLA is the availability and excellence in service.”

“Very responsive and well prepared lawyers; very good knowlodge about company's business.”

A highly respected law firm, the tax department at Lacaz Martins Pereira Neto Gurevich & Schoueri Advogados provides consulting on international and domestic transactions, real estate, tax litigation, judicial litigation, and wealth management. Its tax department is composed of 23 partners and nine qualified lawyers.

During the research period, the team advised Janssen-Cilag Farmaceutica regarding transfer pricing control rules (PRL method) in imports carried out by the company. The relevance of the case relies on the fact that it is the leading case on the matter judged by the Superior Court of Justice, which granted the company’s appeal to recognize the illegality of Normative Instruction 243/2002.

Partner José Luiz Crivelli Filho departed, however, the firm welcomed two new partners Leonardo Thomaz Pignatari and Juliana Cristina de Godoy Arriagada previously from Novotny Advogados.

With more than 95 attorneys and four branches in Minas Gerais State the firm is trusted counsel for a prestigious roster of domestic and international clients. The team of multidisciplinary professionals are specialised across the full advisory spectrum, encompassing preventative audits, tax panning, transactions, and litigation. Supermarkets, telecommunications, petroleum, and wholesalers generate recurrent mandates for the tax practice. Partner Daniel Jardim Sena is a key contact.

During the research period, the team advised Polenghi (Savencia Group). The project was constructed to obtain a special tax regime with the State of Minas Gerais for the actual plant of the company in Minas Gerais, but also for the new plant in Uberlândia which had just been acquired. The firm negotiated with the company’s other tax treatments that could be authorized by the State of Minas Gerais, through a special tax regime that brought direct consequences to the optimization of the tax burden, in addition to simplifying operational procedures.

The firm welcomed three new attorneys: Fernanda Silveira from Manassero Campello Advogados, Guilherme Ribeiro from Martinelli Advogados, and Cláudio Ricaldoni from MRV Engenharia.

Client feedback

“They are good for all the work we asked for them.”

Lacerda Gama is a tax law firm, specialised in the resolution of complex tax issues. Its tax team has experience in administrative and judicial tax procedures for domestic and multinational clients. Service lines encompass litigation, corporate restructuring, outbound transactions, and planning. Key practitioners are partners Tácio Lacerda Gama, Lucia Paoliello Guimarães Chuva and Letícia Tourinho Dantas.

Details of the firm’s cases and clients are to remain confidential.

The firm welcomed senior associate Vanessa Damasceno Rosa Spina in October of 2022.

Barbosa & Ferraz Ivamoto Advogados is a boutique law firm with a focus on tax advisory, litigation, and customs areas. It supports tax planning, operational structures and restructuring, business operations, M&A, and other corporate reorganizations. The team represents clients at all levels of the Judiciary Branch, also provides specialised legal advisory for customs.

The specifics of case matters and clients are confidential.

Lefosse Advogados is a full-service law firm with repute equivalent to the most esteemed Brazilian competitors. Expanding market activity has seen the firm expand to more than 260 lawyers, among whom 44 associates and seven partners are based in the tax practice. Litigation is a particular attribute for sector agnostic clients in domestic and international context.

During the research period, Lefosse advised ArcelorMittal on the acquisition of all the shares of Companhia Siderúrgica do Pecém (“CSP”) from the Brazilian company Vale, and two South Korean companies Dongkuk and Posco. This was one of the largest and most complex M&As transactions of the year.

The firm welcomed two new partners: Dante Zanotti from Organic election and Vinicius Jucá from Tozzini Freire.

Client feedback

“Lefosse is a greatfirm with great tax partners. There are few better law firms in Brazil with respect to international clients.”

“Quality”

“Gustavo Lian Haddad is one of the best in its class when it comes to transactional taxation, tax planning and cross boarder related issues”

“Ana Carolina Utimati is one of the tax controversy partners. Experienced and excellent lawyer.”

Leite, Tosto e Barros provides comprehensive services regarding local, state, and national taxes, including tax compliance, tax planning, and tax litigation. The firm is renowned for litigation at both the municipal and federal levels in precedent setting rulings. Telecommunications, energy, real estate, and financial services are specialist sectors. Partner Carlos Henrique Crosara Delgado is a key firm contact.

During the research period, the team represented two private clients, investors in retail pharmacies, in administrative challenges to two tax assessment imposed by the Brazilian IRS. The case was decided favorably by CARF´s Superior Board of Counsellors.

Client feedback

“Great technical capacity, availability for debates on the topics covered.”

“They are very technical and have a lot of knowledge of the area.”

“The lawyers in the Tax/Fiscal area of Leite Tosto e Barros are always available to their clients, as well as having the expertise in matters linked to this branch of Law to provide excellent advice.”

Sociedade de Advogados Lima Junior, Domene e Advogados Associados mainly advises on tax controversy matters related to ICMS, PIS and COFINS. Its clients act in different sectors such as petrochemical, food and beverage, sugar, and alcohol.

During the research period, the team analyzed the taxation regime for GTI Solution. Its efforts consisted of studying the clients’ operations to implement corporate and tax restructuring aiming at the viability of new partnerships in the areas of technology and insurance, with the possibility of creating an SCP (unincorporated joint venture) an contracts for the provision of technology services.

Client feedback

“Excellent knowledge of the subject, clarity and accessibility to members.”

“Solid knowledge, special dedication of senior partners, agility, clarity in translating tax fundamentals.

“Highly committed professionals, knowledgeable about the company's business, up to date with case law and transparent in their guidelines.”

“Very attentive, dedicated and knows the company's business.”

Founded in 1990, the tax team at Machado Associados operates out of three offices in São Paulo, Rio de Janeiro, and Brasília. The department specialises in transactional tax, including M&A, indirect tax, tax controversy and transfer pricing. Its clients are active in sectors such as construction, healthcare, energy, cosmetics, and consumer goods.

During the research period the firm carried out in depth analysis of the relevant tax aspects and possible tax contingencies regarding a confidential client’s activities in Brazil. The team provided advisory on possible tax optimizations as well as measures needed to mitigate potential tax risks. In addition, the firm worked with Mender Holler Group in coordinating coordinated the analysis of the possible international restructuring alternatives for the Group with presence in Colombia, Chile, Mexico, Uruguay and BVI.

Partners Ricardo Marletti Debatin da Silveira, Carolina Romanini Miguel, Lana Patricia Pereira Baptista, Lorena de Morais Campos Machado, Soraia Monteiro da Matta, and associate Bruna Michaela Di Carlo departed the firm. However, the firm welcomed two new partners, Cecilia Yokoyama and Raphael Okano Pinto de Oliveira, along with a new associate Alessandra Pela Sabbag.

Client feedback

“Machado Associados represented some important companies and is a good peer to work with.”

“Deep knowledge, creative but sound advice, responsiveness”

“M&A counts with very skilled and large experienced professionals on tax matters. Such skills were critical to decide on hiring theirs services.”

“In-depth knowledge of tax matters, agility, good cost/benefit ratio.”

“They are diligent, polite, assertive, direct, proactive and competent in their work.”

“Machado Associados provides accurate analysis and legal advise in different legal areas, which built a trusthworth relationship. I believe that their accounting knowledge is an advantage, as they provide legal opinions not only based on regulations, but also with a financial perspective, which is in alignment with the business perspective.”

“The main positive attribute is the availability. Our consultant is always available to help, mainly on urgent matters that require a fast response.”

The tax team at Machado Meyer Sendacz & Opice operates in three offices in Brasília, São Paulo, and Rio de Janeiro. It is active in tax controversy and transactional tax, including cross-border transactions, M&A, and IPOs. Its clients include sectors such as construction, telecommunications, energy, financial services and oil and gas.

During the research period, the team advised TotalEnergies, a leading energy supplier in the UK, on the tax aspects of structuring and negotiating a joint venture (JV) with Casa dos Ventos (CDV) to develop, build, and operate a renewable portfolio of products. This is the first investment of this magnitude from an integrated oil company (IOC) in the renewable market and the tax aspects are key for the activity. The transaction will help cement the client to reach a leading position in the Brazilian renewable energy market.

Client feedback

“Very competent team, specialized in tax issues.”

“I know many partnets at Machado Meyer and they have a very thorough and detailed analysis with a high focus on clients needs.”

“Experienced in many different transactions.”

“Highly attentive, quick response, thorough work, very knowledgeable.”

The Tax practice of Madrona Advogados advises on a variety of tax matters such as tax litigation, general corporate tax, indirect and transactional tax. It provides services to a broad range of industries such as publicity services, infrastructure in general, transport, automotive, food, agriculture, banking, capital markets, retail, media and entertainment, health in general and planning for high-net-worth individuals.

During the research period, the team represented Novaagri in its writ of mandamus regarding the unconstitutionality of a legal provision that prevents to not subject to the State Transport Fund (FET) requirement by the State of Tocantins, in its operations of interstate output of goods, destined for export.

Three partners left: Felipe Medaglia, Juliano Okawa, Igor Nascimento. As a result of the merger between Madrona Advogados and Fialho Salles Advogados, the team welcomed new partners: Marcos Tranchesi Ortiz, Paulo Roberto Andrade, Patricia Campos Lima, Pedro de Castro Magalhães. Additionally, Paulo Bento joined as a partner previously from Watt Investimentos.

Client feedback

“In addition to technical expertise, madrona has operational knowledge of our business and is well considered in our market. Thus, madrona has the ability to help us not only based on legislation, but taking into account the practical problems related to the subject.”

“Qualified professionals, excellent service.”

Mallard Medeiros is a full-service law firm, with multidisciplinary expertise including: advising on M&A transactions, corporate structuring and restructurings in general, structuring of infra-structure projects, advising on the corporate structuring of real estate projects, domestic and international tax planning, customs regulations but also, daily consulting, such as domestic business activities and transactions. Sectors services include Healthcare, Mining, Services, Technology, Life Sciences, Agribusiness and Real Estate.

During the research cycle the firm assisted SJK Capital Group in analysing the feasibility and impacts of the increase in share capital, and planning/restructuring the group's capable, including the study of the feasibility of merging some of them and the possibility of using the goodwill in an amount of approximately thirty million reais.

Founded in 2004, Mannrich e Vasconcelos Advogados specialises in working with the healthcare, chemical, agribusiness and mining sectors. Its tax team is active in tax controversy and general corporate tax. Partners Breno Ferreira Martins Vasconcelos and Thais Romero Veiga Shingai are key individuals at the firm.

The firm is representing Instituto Sou da Paz regarding the Action Against the Violation of a Constitutional Fundamental Right No. 772, which is a leading case in the Supreme Court and involves the reduction of the customs duty on the import of fire guns by the Resolution No. 126/2020 of the Executive Committee of the Foreign Chamber of Commerce. As leading case in the Supreme Court, this case has a significant impact on all other lawsuits about this subject. The matter is also relevant because the action aims to reduce the access to fire guns by the civil society, which could violate constitutional rights that guarantee life, human dignity, and public safety due to the fact more people could die from the increase of fire guns in circulation.

Client feedback

“Superb technical content and fisrt-class professionals. Great responsiveness and deadline matching.”

Founded in 2003, Marchiori Sachet Barros has branches in São Paulo, Rio de Janeiro, Florianópolis, Manaus and Brasilia, and has more than 140 staff members of which 100 are lawyers of solid legal training, including 12 partners. The Tax Department is composed of Litigation, Consulting and Advisory divisions. The firm stands out in the economic segments of retail, logistics, industry, telecommunications, beverages, energy, oils and gas, infrastructure, mining, port sector and shipyard, new technologies, sugar and alcohol production, air, rail transportation and shipping.  

During the research period the firm was involved in advisory for several national companies in the telecommunication industry to present to ANATEL (National Telecommunications Agency) the fiscal regularity of the companies with the purpose of approving the incorporation project for the consortium purchase enabling the 5G auction.

Two junior partners, Gustavo Teixeira Domingues and Marcos Orind de Oliveira departed in January of 2023, along with senior partner Mariana Kapps Coutinho leaving in March. The firm recruited a new junior partner, Karina Neves Gutermann.

Marcos Martins Advogados is a law firm with outstanding expertise in Tax and Corporate. It is prominent in Dispute Resolution and Labor services. Sector strengths include the Manufacturing, Polymer Producer and Metallurgical sectors.

During the research period, the firm represented Enterpa on tax-related matters during a court restructuring proceeding, analyzing all scenarios available for our client’s regularization. The execution of the work done will allow the client to avoid being surprised by blockages and seizures, while also adapting the debt to its cash flow.

The firm welcomed Rafael Zanchetin and Aline Augusta de Menezes. Alana Aiche do Carmo Dahrouj left the firm in June of 2022.

Mariz de Oliveira e Siqueira Campos Advogados has over 40 years of experience in the market. It is widely acclaimed for its tax consultancy and litigation expertise, tax aspects and complexities of domestic and cross-border situations and transactions, and for its experience advising blue-chip clients on a full range of sophisticated, strategic, and sensitive tax issues, such as tax planning, M&A deals, capital markets transactions, corporate reorganizations, real estate transactions, customs taxes, and private wealth.

During the research period the team advised JP Morgan in the acquisition of C6 Group. It assisted Banco JP Morgan in several tax aspects, including the purchase price allocation, which is an essential step for the tax amortization of all intangible assets acquired and the goodwill assessed in such business combination.

Client feedback

“The services are rendered with technical promptness and in-depth knowledge of the matter under discussion.”

“The law firm is always accessible and available. They are also always up to date on the most relevant tax issues.”

“Very high level of technical knowledge, positive attitude in receiving suggestions creating a productive work environment even in a high pressure situation with a very strict deadline.”

“The lawyers who work at the firm have great expertise in tax matters, facilitating decision-making in complex issues.”

“Mariz de Oliveira offers a great law services, because the role team of lawers is very competent and tax knowledge in several different segments (services, industries, etc).”

“Professionals are excellent, organized, deliver depth analysis of the cases. They are great on income tax, VAT, tax planning.”

Just founded in February 2023, Martins | Villac acts in the areas of real estate, tax, corporate and M&A, contracts, structured operations of enterprises and businesses, labor law, civil litigation, and asset management. The tax department advises in matters such as structuring compensation models applicable to top executives in multinationals, including stock option, LTI, RSU; debt financing transaction, including debentures, commercial papers, real estate bonds etc.; structuring tax planning both for the buy side and the sell side, with the purpose of reducing the tax burden on capital gains, considering different procedures of paying (receiving) the acquisition price, and also inbound corporate and family business reorganizations with the scope of a more efficient tax structure and wealth-planning advice.

During the research period, the firm advised FCB Brasil Publicidade e Comunicação with a cross-border crypto asset deal with a triangular transaction.

The tax department at Matarasso Advogados provides services including but not limited to: Tax planning of enterprises, companies, infrastructure projects, equity and succession, Tax consulting covering all aspects and themes of Tax Law, involving the daily life of companies and individuals, and Tax and Social Security revision, covering administrative and, if necessary, judicial works. The team's work is broad, covering both the advisory and litigation spheres, in relation to all types of taxes.

During the research period, the team represented Planejar by filing of a lawsuit to declare the non-requirement to pay ISS on royalties arising from the assignment of the right to use a brand. The action was upheld to declare undue payment of the ISS levied on royalties remitted abroad as part of the licensing of the right to use the trademark.

The firm welcomed two new associates: Manoella Frazão Diógenes previously from Sacha Calmon Misabel Derzi Consultores e Advogados – SCMD and Paula Morcelles who was promoted.

Client feedback

“Real Estate development.”

“Knowledgeable, efficient, and timely.”

“They are very committed, focused and have a very good service.”

Mattos Engelberg Advogados provides both tax legal consulting services to national and international individuals and companies, in the most diverse Tax topics and customs fiscal issues, covering the most varied economic segments and taxation spheres involving Federal, State and Municipal Taxes.

During the research cycle, the team defended Tereos Acucar e Energia Brasil against a received Notice of Violation drawn up by the State of São Paulo. The team showed, in this context, that once the transfer of ownership of the ethanol with the delivery of the goods to the buyer is effective, any liability of the seller ceases, who cannot be held responsible for the other destination of the goods.

Partner Priscila Farisco departed to Viseu Advogados in January of 2023. However, the firm recruited various new practitioners including partner Wolmar Esteves, senior associate Felipe Scandiuzzi, Junior Associate Beatriz Odilon Barreto, and Mid-level Associate Bruna Ceotto Gomes.

Mattos Filho Veiga Filho Marrey Jr & Quiroga Advogados is active in the financial services, life sciences, chemical, oil and gas, energy, pharmaceutical, automobile and IT sectors. It specialises in indirect tax, tax controversy and transactional tax, with an emphasis on M&A and corporate reorganisations. The firm operates out of three Brazilian offices in São Paulo, Rio de Janeiro and Brasília. Partner Alessandra Gomensoro is a key individual at the firm, which consists of over 100 professionals including 23 partners.

During the research period, the firm advised Actis Assessoria Investimento in the sale of 100% of its stake in Atlas Renewable Energy to Global Infastrcture Parterns (GIP). Aditionally, the team advised the sellers and current shareholders of Grupo Big Brasil (former Walmart Brasil) to Atacadão (Carrefour Group). The closing of the transaction occurred on June 6, 2022, after the satisfaction of certain conditions precedent, including CADE’s approval, which imposed remedies to be implemented post-closing.

Client feedback

“I consider Mattos Filhos as the leading firm in terms of Tax in Brazil.”

“I believe that, among the big law firms, Mattos Filho has one of the strongest tax teams, with partners specialized in the various fields of tax.”

“Led by Roberto Quiroga, the tax department of Mattos Filho has vast experience in providing tax legal services.”

“Led by Roberto Quiroga, the tax department of Mattos Filho has vast experience in providing tax legal services.”

“One of top law firms in Brazil.”

“Is a great and tradicional firm.”

“Because of their professional capability.”

“Market reference; expertise; professionals who are highly knowledgeable about the subject in question; clarity in the information provided.”

“They work toguether with the client, bring solutions to be discussed.”

“They are responsible, have a great budget and good knowlegment in tax issues.”

“Mattos Filho law firm is a full-service provider. The team is highly technical and investigate deeply the issues. They are 100% immersed in visual and digital law, and they have a great observatory that monitors Brazilian tax administrative and judicial jurisprudence.”

Mauger Muniz Advogados was founded in 2017 with expertise in several sectors such as commerce services, automotive, banking and finance, estate and succession planning, telecommunications, electronics, food and retail. Services include Tax Planning and Tax Litigation legal advice, Wealth and Succession Planning advice, assisting our clients with the legal procedure that defines how the transfer of assets is carried out while the person is still alive or after the person's death.

During the research period the firm advised Velans Teleinformática. The case was a cross-border operation that demanded a multi-disciplinary approach and deep knowledge of technology systems to provide support. The challenge was to try to align the foreign producer interests with those of the Brazilian tax structure to get the product at a competitive price. The firm assisted Velans with the drafting of the sole agent contract agreement with Yealink. This agreement was related the import of the video-conference system which led to the company winning the Petrobras bid.

The team recruited partner Allan George de Abreu Fallet and senior associate Enzo Romero Rodrigues, both previously from LTSA.

Client feedback

“I aprreciate the staf'f's expertise on tax matters and the commitment to delivery according to the deadlines agreed.”

“Easy access to Partners; quick return; they understand the reality of the client and are very fair and flexible in the fee collection format.”

“They have a careful look at the client, and try to provide comprehensive answers and recommendations. They try to understand the business and be a partner, not a simple advisor.”

Mauler Advogados in based on the states of São Paulo and Brasília and provides monitoring in consulting, administrative and judicial litigation, and tax litigation, working throughout the fields, including in the Superior Courts. Lawyers work pro bono for various entities and non-governmental organizations with special attention to legal issues regarding excessive collection of taxes.

During the research period, the firm defended its client in an action regarding the unconstitutionality of tax matters. The possible favorable trial result will benefit the entire sector.

Thabitta Rocha left to Minatel Advogados in July of 2022. However, the firm welcomed four new partners: Luan Moreira, Regina Araujo, Natalia Molina, and Paulo Boechat.

Client feedback

“They are atencious, and highly technical.”

“They frequently interact with the in house team and seems they are part of it. They make their best to understand the company´s business and what can be done to improve it.”

“They are trustable and fast.”

“Confidence. Quick answers. Expertise”

Mazzucco & Mello's tax practice stands out for combining extensive technical, sectorial, and corporate knowledge with customised client service. The firm has expertise in all matters related to taxation, including assistance in defence of tax assessments, tax recovery and general tax advisory. Partner and tax litigation specialist Guilherme Henrique Martins Santos is a key individual at the firm.

During the research period the team advised Zeta Importação e Exportação. It worked to manage and cancel over R$ 40 million in federal libailties related to the discussion on the leigitmacy of the requirements of federal taxes on import operations of goods subject to relief. Efforts undertook required an innovative methodological look at the topic, both from the perspective of the customs issues involved, as well as the use of the tax transaction.

The firm welcomed senior João Pedro Riccioppo Cerqueira Gimenes previously from Mazloum Advogados.

Founded in 2008, Melcheds Advogados boasts a specialised tax law department, capable of representing clients on both the administrative and judicial levels. The team specialises in tax advisory, tax planning and tax litigation and disputes work. Founding partner and tax litigation specialist Roberto Rached is a key individual at the firm.

During the research period, the team worked with client, Fadel Transportes e Logistica, in filing a Writ of Mandamus.

Client feedback

“Extremely precise, punctual, efficient.”

Bruno Sartori de Carvalho Barbosa heads the tax department at Souza Mello & Torres Advogados, supported by a strong team of partners and associates. The department specialises in transactional tax, litigation, general corporate tax, and indirect tax. It is active in the pharmaceutical, technology, oil and gas, telecommunications, retail, engineering, energy, mining, and industrial sectors.

During the research period. The team advised the 129 billion reais (US$21 billion) merger of local health insurance companies Hapvida and Notre Dame, marking the country’s largest corporate tie-up in more than a decade.

The firm welcomed three new associates, Bruno Ippolito from Mariz de Oliveira e Siqueira Campos Advogados and Bruno França Poggianella from Maneira Advogados. Giulia Kohl Abdalla was promoted in January 2023.

Client feedback

“Strong technical experience. Use of useful market benchmark for our business. Engaged professionals and a differentiated customer-oriented approach. Efficient monitoring of the entire process.”

“Good service, avalibility and outstanding techinical knowledge.”

“Deep knowledge of the Brazilian market. Provide clear alternative, risk and opinion. Good relationship, flexable and adaptive.”

“Knowledge and accessibility.”

“SM&T is a highly qualified law firm, with a proactive attitude and focused on results, his contributions were a differential for the smooth running of the work.”

Miguel Neto Advogados’ tax team is divided into tax advisory and tax litigation. The tax advisory team works closely with specialists in other areas and practice groups, such as corporate restructurings, mergers and acquisitions, banking and finance, labor, real estate, foreign investment, and estate planning. The tax litigation team specializes in tax appeals at the administrative and judicial levels and advises on tax disputes, tax ruling requests and protocol negotiations with tax authorities. The firm also advises in transfer pricing matters.

During the research period, the team assisted Café Três Corações Alimentos. The lawsuits have not yet been definitively ruled, however during 2021 there was a reduction of approximately 50% of the total amount. The estimate is that the remaining amounts shall be fully canceled. The firm worked to provide a solution that brings greater economic efficiency.

The team welcomed two new senior associates: Danielle Caldeirão Santos Castilho previously from Demarest, and Lucas de Souza Araújo from Ayres Ribeiro Advogados.

Client feedback

“In MNA they are always available and with good will to solve company`s demands. Also, they have an assertive conversation and show good knowledge of the system and bring good insights.”

“The whole team is accessible at any time we need and we are confident that they are very up do date on the tax relevant matters to our business. The communication is objective and we feel that the solutions suggested by the team are differentiated, since it is not only foccused on the legal perspective, but they are also concerned to provide us with the options that most make sense to our business and financial aspects.”

“MNA acted very diligently and also efficiently. I was kept informed at all stages.”

“The whole team is accessible at any time we need and we are confident that they are very up do date on the tax relevant matters to our business. The communication is objective and we feel that the solutions suggested by the team are differentiated, since it is not only foccused on the legal perspective, but they are also concerned to provide us with the options that most make sense to our business and financial aspects.”

“Strong availability, excellent knowledge and focus to deliver radiply key information needed for the M&A operation.”

“Miguel understood well our needs and in fast time return the contracts and anlisys about our operation.”

Founded in 2017, MJ Alves & Burle Advogados & Consultores has a tax team specialised in tax controversy and tax advocacy. Its clients come from a wide variety of industry sectors such as oil and gas, construction, and energy. The team prides itself on the 360° tax strategy it applies to each of its clients. Founding partner and tax litigation specialist Marcos Joaquim Gonçalves Alves is a key individual at the firm.

Throughout several research periods, the firm advised Energética Serranópolis, and obtained a favorable decision in one of the cases that reached the Superior Court of Justice. The work done was responsible for savings of approximately 35 million reais for the client and will end nearly 22 years of litigation with the Brazilian tax authorities and about 300 judicial proceedings.

During the research period the firm welcomed two new partners: Leandro Bettini from Mattos Filho, and Adriana Rocha Abrão from the Tribunal de Contas do Distrito Federal e Territórios. Additionally, the firm recruited an associate lawyer, Yasmim Beatriz Silveira Santos.

Client feedback

“Professionalism, competence, kindness and prompt responses. MJAB establishes action strategies in a clear and objective way in very complex and nationwide cases. This is the firm to go when the case requires complex analisys and the study of political and judicial decisions, and advice on pending legislative proposals.”

“They know the legislation and the people at PGFN who carry out the transactions well.”

Monteiro e Monteiro Advogados Associados was stablished in 1990 with offices in Recife (headquarter), São Paulo, Brasília, Rio de Janeiro, Fortaleza, São Luís and Salvador. The team advises on consulting and planning services in corporate and administrative/constitutional law, and it is mainly focused on tax litigation. The firm has expertise in associations of vehicle assemblers as well as on fuel distribution.

Starting in 2006, the team represented Pague Menos before one of the Federal Regional Courts, in a collective Writ of Mandamus that aimed at the recognition of a high volume of Federal Taxes (PIS and Cofins) to be recovered by the client, anchored in the Law 11.033/2004. Through industrious work developed, the ministers of the First Chamber of the Superior Court of Justice ended up granting the Special Appeal of Pague Menos, recognizing the right to maintain the credit of the monophasic PIS/COFINS. Such decision was the first positive legal precedent on the matter in Brazil, serving as a precedent for all the other suits dealing with the controversy, in all instances.

Gilma Carvalho left to start a solo career as a medical lawyer. Additionally, the firm promoted Bruna Miranda as the head of oil & gas royalties and public Biddings.

Client feedback

“Conhecimento aprofundado da área e agilidade na prestação de serviço.

“Monteiro e Monteiro displays professionalism and efficiency when dealing with the client. They are very dilligent on informing the most recent decisions to us - even the bad ones! This helps building a relationship of trust and colaboration. We are happy our partnership has generated good fruits!”

“Monteiro e Monteiro has showcased really deep technical understanding of tax discussions, and a good commercial attitude (in the sense that they usually come talk to us when there are new tax discussions happening). They also communicate well and directly with us, with no need of legal jargons!”

Nelson Wilians Advogados has been investing in tax technology since 2014. The firm employs a wide range of innovative technologies to benefit its clients, including query and process management tools, process base certification tools, document automation, analytics tools, and dispute monitoring. Tax partner Olímpio José Ferreira Rodrigues is a key individual at the firm.

During the research period, the team assisted Conterma Energia in recalculating the interest applied to the debt and identified that the company is a creditor, demonstrating that the amounts paid in the past exceed the debt amount considering the correct percentage of interest. So far, it has been possible to suspend the debt, avoiding future collection of taxes, and in the future, we are awaiting receipt of the amounts.

NHM Advogados advises on a variety of tax matters, including general corporate tax, customs, indirect tax, tax compliance, M&As and tax litigation. The firm’s tax department is led by Florence Haret Drago.

Details of the firm’s work and clients remains confidential.

In 2019, Numeris Consultoria opened its newest office in Belo Horizonte, joining the firm’s existing office in São Paulo in providing consultations in financial, accounting and tax services. The firm specialises in general corporate tax and indirect tax, with clients belonging to numerous sectors such as telecommunications and IT. Partner and corporate tax specialist Ana Carolina Moreira Garcia is a key individual at the firm, which consists of 6 specialised professionals.

During the research period the team assisted Schneider Electric Brasil on the revision of the accounting methodology. The firm opted to swap operations related to loans on foreign currency and calculation of the tax implications.

Two senior tax advisors, Ana Beatriz de Almeida and Igor Vieira, left for Lacerda Diniz e Sena Advogados and Portugal Vilela Advogados, restively. However, the firm recruited a new senior tax advisor Vinícius Martins Moura from Fialho Salles and partner, Maysa de Sá Pittondo Deligne who was previously in CARF.

Client feedback

“Numeris has highly prepared professionals, who provide us with reliable opinions, a safe technical basis, within the legislation and with a search for efficiency and economic intelligence. We were very comfortable hearing the opinion of the Numeris Team due to the ethical stance of the partners. Our Company is conservative and finds clarity and compliance in Numeris guidelines. We have been successful in the guidance of consultancy professionals, achieving safe results within ethical and legal standards, with timely deadlines.”

“Domain of particular details about tax in Brazil, collaborative, providing instructions and details about of the obligations required by fiscal authorities.”

“Antonio has a great knowledge on hedge/swap calculation in terms of Forex, interest and financial impacts, reconciliation of accounting and corporate taxes impacts.”

The team at Oliveira Alves Advogados advises specially in tax litigation, indirect tax, and general corporate tax. The firm’s clients are judicially and administratively represented before the federal, state, and municipal levels. Within the tax advisory, the team provides tax planning, prepare technical analyzes and formulate preventive strategies to avoid legal problems and maximize positive business results. The firm works with a variety of industries such as aeronautics, automotive, food, agro-industrial, wholesale commercial, beverages, civil construction, energy, hotels, technology, pharmaceuticals, finance, petrochemicals and steel.

During the research period, the firm advised Rosenberger Domex to identify main opportunities in the judicial tax sphere, aiming to optimize the tax burden and reduce the company’s operating costs. Recently, the firm filed a lawsuit to assure the recovery of amounts unduly paid with the Siscomex Tax, due on import operations, to reduce tax burdens on the import of products essential to the company's activity.

Client feedback

“Great partner of Yamaha, very attentive and available to attend Yamaha's needs.”

The tax team at Padis Mattar Advogados is known for offering solutions to tax issues arisen from complex cross-border transactions, including M&A, restructuring and project finance. The firm works to provide in depth tax consultancy both in advisory and litigation areas. The spectrum of work on tax advisory comprises all three government spheres (federal, state, and municipal taxes) and features the compliance with tax obligations, due diligences, tax incentives and the monitoring of special regimes, with focus on the aviation, banking, pharmaceutical and energy sectors.

During the past year, the team represented Ad Hoc Group of Lenders and Bondholders of Samarco in the judicial reorganization filed by Samarco in April 2021 (“JR”). Tax advisory was provided including: the tax planning of the alternative plan proposed by the AHG under the recently amended JR Law; assistance on measures as to mitigate any potential tax liability derived from the JR; revaluation of Samarco’s tax liabilities as per their published financial statements; assessment on the possibility and requirements in order to execute tax agreements before federal tax authorities in accordance with the new tax transaction law; among other tax consultancy activities in connection with the restructuring.

Peixoto & Cury Advogados is a medium-sized firm with a tax team led by two partners and nearly 20 years of substantial tax and accounting experience. The firm advises national and multinational firms with expertise in areas such as corporate tax, international tax, tax structuring, transactions, real estate, litigation, and tax planning. Tax partner Renato Vilela Faria is a key individual at the firm.

During the research period the team provided tax assistance to M Shop Comercial. The case was a unique tax exemption case in the sense that the client imports and resells Lego Products, some of which are the Lego Education line of products. However, these products have a tax classification of toys in Brazil, not of books or other educational products, having normally taxes as ICMS, IPI, PIS and COFINS in its price, both for import and resale. A lawsuit was filed claiming that the product should have tax immunity as ICMS and IPI and zero rate of contributions to PIS/COFINS.

Paulo Fernando Melo is the managing partner at PFM Associados, a new firm established in 2017. It has two offices in Rio de Janeiro and São Paulo and is active within the oil and gas, energy, natural resources, manufacturing, and private equity sectors. The team specialises in general corporate tax, compliance, corporate restructuring, due diligence, indirect tax, and transactional tax, especially M&A.

The team, since 2021, has been the local advisors to Zwift when it comes to tax/corporate advisory and local business process outsourcing. The team is involved in the structuring of transactions, international tax analysis, tax advisory on indirect taxes, payroll taxes and all taxes pertaining its activities in Brazil.

Client feedback

“PFM has a whole brazilian taxes expertise.”

“Excellent services , great knowledge and cliarity to explain”

Pinheiro Guimarães provides legal advice in the different areas of tax law. In addition to advocating proficiently in tax disputes at all jurisdictional levels, in both administrative and judicial proceedings, Pinheiro Guimarães provides tax-advisory services covering the entire spectrum of tax law, domestic and international.

During the research period, the team acted as counsel to Enel Group and the Target Company in connection with the acquisition of Celg-D by Equatorial Energia. The team assisted in all steps of the transaction including the structuring of the deal, the draft and negotiation of the Share Purchase Agreement and its ancillary documents, the due diligence and the risk assessment of all issues identified. The acquisition is pending approval from Brazil’s Administrative Council for Economic Defense (CADE) and the National Agency of Electric Energy (ANEEL).

Client feedback

“Pinheiro Guimarães perfectly understands our internal needs and culture.”

Founded in 1942, Pinheiro Neto Advogados is a full-service firm with offices in São Paulo, Brasília and Rio de Janeiro. The tax team specialises in transfer pricing, general corporate tax, tax controversy and transactional tax, specifically M&A. Sérgio Farina Filho is the senior partner in the tax department. Clients include members from industry sectors such as consumer goods, IT, telecommunications, pharmaceuticals, entertainment, cosmetics, and agribusiness.

During the research period, the team provided counsel to Cosan Lubrificantes e Especialidades in judicial litigation against a BRL 1.3 billion tax enforcement claim of withholding income tax (WIT) with respect to the capital gain attributable to Exxonmobil in the alleged sale of Esso do Brasil, a major distributor of fuel, petrol-products and gas-station operator in Brazil, to Cosan. This is high profile case whose outcome may impact reorganization structures and shed more light on a much controversial but seldom litigated provision for WIT taxation of persons not domiciled in Brazil.

Two partners retired, Sérgio Farina Filho and Ricardo Becker. However, the firm promoted three new partners: Renato Caumo, Vinicius Pimenta Seixas, and João Rafael L. Gândara de Carvalho.

Client feedback

“Pinheiro Neto is tier 1.”

“Pinheiro Neto is one of the most traditional law firms in Brazil, and is well posted in the legal market.”

“Is a great and tradicional firm”

“The team is very helpful, always responding and helping when we need it. Pinheiro Neto's knowledge on tax matters is outstanding.”

“They are fast, super technical, engaged and are able to help me with benckmarks.”

“Technical knowledge and benchmark.”

“Great knowledge, quick response to emails, good price.”

“They have a great team in administrative tax litigation.”

“Highly responsive with value-added advice.  Always searching for solutions and demonstrating a great commitment to client service.”

“100% responsive with top quality lawyers.”

The tax department at Queiroz e Lautenschläger Advogados advises on tax controversy and general corporate tax matters. National and foreign companies, as well as individuals, are constant clients at the firm. Among their current clients are Banco Bradesco, Telefônica Brasil and Sindicato das Empresas de Asseio e Conservação no Estado de São Paulo.

During the research period the team advised Sindicato das Empresas de Asseio e Conservação no Estado de São Paulo (SEAC) on an opportunity to reduce its tax burden. If successful, all associated companies will be able to benefit from the decision handed down in the records of the case they are following, which is very representative for the category.

The firm welcomed partner Rodrigo Leal Griz, previously from Lefosse.

Client feedback

“QLA does a meticulous job of collecting information and analyzing it, discusses it with us in an iterative and clear way for those without legal training, welcomes relevant contributions, in a process that involves our team, provides security, peace of mind and empowers it.  In addition, we have a track record of working together for over 25 years with complete success, there has never been a case where their guidance has not been fully effective.”

“They orientate our company to comply with taxation obligations, in the prevention of risks, in the identification and mitigation of existent tax liabilities, through: Preparation and execution of taxation planning; Issuing of legal opinions; and Analyses of fiscal and taxation practices.”

The tax department at Rayes & Fagundes Advogados Associados is over 23 years old, with offices based in São Paulo, Rio de Janeiro, and Campinas. It is the go-to firm for pharmaceutical companies looking for tax advice and representation in Brazil. The team covers the full gamut of tax services, including litigation, tax planning, due diligence, advisory, corporate tax, indirect tax, transfer pricing, restructuring, HNWI’s, real estate and M&A transactions. Tax partner Ronaldo Rayes is a key individual at the firm.

During the research period, the firm advised Boehringer Ingelheim Animal Health do Brasil with a transfer pricing mandate. The client was granted a preliminary injunction by the court. The firm is current waiting for the appeal decision.

Rivitti e Dias Advogados is a law firm focused on tax law with services including advisory, consulting, administrative and judicial dispute resolution services regarding tax law for Brazilian and foreign individual and corporate clients from various business sectors. The tax advisory practice offers solutions for new business models, with an emphasis on the optimization of the tax burden and the management of risks.

During the research period, the firm advised its client on the legal provisions on transfer pricing adjustments. This case reflects the ongoing change in Brazilian transfer pricing legislation. Although the Provisional Presidential Decree has yet to be approved, the new criteria introduced in the legislation are still subject to discussion – especially regarding their application by the Brazilian Federal Revenue Service.

Client feedback

“Trust and knowledge.”

A well-established firm in the Southern region of Brazil, Rossi, Maffini, Milman & Grando Advogados has an outstanding reputation for tax litigation, acting before administrative and judicial courts for clients from a broad range of industry sectors. Tax partner Felipe Grando is a key individual at the firm.

During the research period, the firm represented Arauco Industria de Paineis by filing an appeal to the Administrative Court of Tax Appeals - TARF/RS, reiterating the detailed and complex demonstration of the relevance of each disallowed item, as well as the procedural nullities. It was possible to partially reverse the unfavourable outcome given to the case, in the sense that the TARF determined the conversion of the deed into diligence for a new conference of the disallowed items. This decision was published in August 2020, pending the return of the due diligence.

Client feedback

“Lawyers with excellent qualifications, in-depth legal knowledge and ease in Brazilian courts.”

RVC Advogados consists of distinguished group of specialists (25 partners and 134 non-partners) who work in a collaborative and complementary way in the tax, corporate, labor, and social security areas. Specific to tax, the team offers client solutions for both administrative and judicial tax litigation matters, within the municipal, state, and federal level, as also provides legal and consulting services related to direct taxation, indirect taxation, international tax, customs, and social security issues.

During the research cycle, the team advised its client with tax efficiency and operational tax planning regarding direct taxation. Utilized for the case, RVC developed an important technological tool for the treatment and manipulation of tax and operational data. The implementation of tax opportunities has a positive impact on companies' cash flow, reducing the amounts that are disbursed monthly to pay taxes.

The firm welcomed two new partners: Cassius Vinicius de Carvalho previously from Garrigues Brasil, and Fabio Perrelli Peçanha from Neiva, Barros & Figueiró Sociedade de Advogados.

Client feedback

“This ranking is align with the profile of our law firm.”

“We already had a favorable decision related TP dispute in the first and second administrative instance. We already have favorable decision to be refunded in the VAT Credit since 2017.”

“Thy are Experient, Fast and integrity are some skills from them.”

“Great technical knowledge, made great connections between legal and business requirements, reliable in terms of dates and deliverables commited.”

“Excellent response time on complex demands; availability for last-minute queries.”

SABZ Advogados is known for its embracing all economic sectors, however, taxation on real estate business, agribusiness, insurance and reinsurance are its main strengths. In 2019, the sector started acting in tax class actions, in the name of Class Entities. The team has members in the Brazilian Rural Society Tax Committee (SRB), Real Property Law Committee (IBRADIM) and Tax Arbitration and Transaction Committee (IBATT), leading important disputes, which impact all Brazilian companies that deal with Agribusiness, Infrastructure, and Real Estate.

During the research period, the team advised Grupo Ekko in developing its tax planning while aiming to obtain the best tax efficiency regarding costs. In addition, the firm supported Construtora e Casa with the structuring of a corporate and tax model to enable the company’s expansion of its numerous stores through the issue of transferable securities.

Sacha Calmon Misabel Derzi Consultores & Advogados is a leading Brazilian tax boutique, spread across four national offices. The team has outstanding expertise handling tax litigation, tax planning, international tax and indirect tax, with clients from a variety of industries including telecommunications, mining and steel, food and beverage, construction, automobile and healthcare. Founding partner Sacha Calmon Navarro Coêlho, with nearly 60 years of experience, is a key individual at the firm.

During the research period, the team advised Bunge Alimentos on judicial claims and administrative defenses in several States discussing the client’s right to ICMS (Tax on the Circulation of Goods and Services) credits in operations covered by tax benefits. In some cases, the decisions were issued in favor of the client, with the states recognizing the binding effect of the new Federal Act that validated the previous tax benefits.

Client feedback

“They are superb in technique.”

“They are a very trustable firm, who provide legal opinions and really helpful advices to the companies. We have known each other for years, and have worked together before.”

“Sasha Calmon Misabel Derzi Advogados is a reference in the tax law sector. They have great track record and client portfolio. Their lawyers are solid voices in the grand tax discussions that take place on the Supreme Court.”

“Seriousness and technical competence.”

Founded in 1992, Santos Neto Advogados is a full-service law firm, with its clients mostly operating in the financial services, agriculture, family business, and technology sectors. The tax team specialises in tax controversy, transactional tax, transfer pricing, indirect tax, and general corporate tax. Tax partner Henrique Munia e Erbolato is a key individual at the firm.

Santos Neto Advogados has advised Alphaville Group in the incorporation of a joint venture with RCG Engenharia e Empreendimentos for the development of the Terras Alpha Uberaba real estate project, for residential allotment with a total area of 347,570.20 m2. This case represents a trend of increased transactions in the real estate industry in Brazil.

The firm welcomed associate Julia Figueiredo previously from Tozzini Freire.

Client feedback

“For tax on agricultural matters, they are very good.”

“Proactivity, knowledge.”

“Risk analysis in the interpretation of legislation and guidance for the correct accounting of company assets.”

“Punctuality, availability and assertiveness. Excellent technical partners.”

“Santos Netos team is very well prepared. The entire team shows a deep knowledge about the matters discussed and they are always availble responding prompt ours requests.”

Schneider Pugliese Sztokfisz Figueiredo & Carvalho Advogados specialises in tax controversy, indirect tax, and tax planning. The boutique firm spans two offices in São Paulo and Brasília and is comprised of five partners. Its clients represent multiple sectors such as financial services, consumer goods, automobiles, pharmaceuticals, agribusiness, and cosmetics. Partner Henrique Philip Schneider is a key individual at the firm.

During the research period, the firm advised Zurich Santander in the writ of mandamus aiming at the recognition of the Company’s right not to include the brokerage fee passed on by the insurance company to its brokers in the tax base of the Social Contributions on Gross Revenue, on the grounds that said fee does not constitute part of the insurance company’s gross revenue, but a mere transfer to its brokers. In December 2022, the Federal court granted the writ of mandamus. This decision is not yet unappealable. The importance of the case relates not only to the matter itself, but also to its scope (since it is applicable to every insurance company in the country) and to the financial impacts.

Partner Flavio Eduardo Carvalho departed to Manera. However, the team welcomed three new senior associates: Breno do Carmo Vieira, Thales Belchior Paixão, and Andrea Marco Antonio.

Client feedback

“They act with great technique in Federal Administrative Court (CARF) and Judicial Courts.”

Silva Gomes Advogados provides a highly specialised and personalised service to clients including SME’s and multinationals, with extensive expertise in tax litigation and disputes, due diligence, customs, and tax consultancy. Founding partner Luis Augusto da Silva Gomes is a key individual at the firm.

During the research period the firm worked with Confederação Nacional das Revendas AMBEV e das Empresas de Logística da Distribuição (CONFENAR) as it filed a class action on behalf of the Distributors of Goods from AMBEV (a renowned beverage industry in Brazil and abroad). The Companies should recover the unduly payments of PIS and COFINS since the last 05 years from the filling of the lawsuit.

Client feedback

“Very experienced partner in the litigation field.”

Siqueira Castro Advogados is a full-service law firm. It is active in most sectors including agribusiness, automobile, construction, education, energy, food and beverage, financial services, healthcare, entertainment, logistics, mining, oil and gas, pharmaceutical, retail, technology, telecommunications and sports. Over 100 professionals make up the tax team, which specialises in indirect tax and tax controversy. Partner Maucir Fregonesi Junior is a key individual at the firm.

During the research period, the firm advised Prefab Construções Prefabricadas in various Tax Foreclosures filed by the General-Attorney of National Treasure, claiming the Company’s liability for third parties tax debts, under the argument that the Client belongs to the same economic group as the tax debtor.

Partner I Jen Huang left the firm in March of 2022.

Sonia Marques Döbler Advogados was founded in 1996. The Tax Department offers a multidisciplinary service, but still specialized, in the preventive, advisory and litigious performance in the protection and defence of clients' interests.

Details of the cases and clients are to remain confidential.

Client feedback

“Service. Agility. Punctuality. Security.”

“Sonia Marques Dobler Advogados is specialized in several areas and could provide high technical support for a Company established in Brazil.”

“The office is supported by good professionals, we receive feedback and process evaluations quickly and clearly. The monthly monitoring spreadsheet is updated with comments and status of each process. We receive the newsletter which helps with recent updates and changes.”

“Knowledge, security, efficiency, punctuality, cordiality.”

“Always available and the team is very capable. All demands are answered with the minimum of detail.”

SouzaOkawa was created in early 2023 previously Madrona Advogados. The team provides assistance in the following matters: Direct Tax Consulting developing studies and opinions on tax issues and tax collection structuring; Tax Planning with analysis of the client's operation and proposal of tax structures; International Taxation with evaluations of different international tax structures to support efficient business development; Tax Litigation representing national and foreign clients in judicial demands in all courts; Administrative Tax Litigation sponsoring clients' cases before the Administrative Tax Appeals Defense Council (CARF).

During the research cycle, the team was involved in the merger transaction between Hapvida and Intermédica that created one of the largest healthcare groups in the world. The work included all tax impacts of the structure and Due Diligence. Also, the firm acted in the incorporation of Hemmer by Kraft Heinz. Its work consisted of the analysis of all tax aspects of the restructuring. Other details of cases are to remain confidential.

Client feedback

“Its partners alre always involved in the deiscussions, the seem to kee a laser focus and business oriented that help them achieving the best solutions.”

“Souza Okawa is a firm focused on providing tax advisory taking the whole context of the Company, not just the specific question about tax. That brings a lot of insights for the clients.”

“Excellent service. Very strong tax litigators.”

Stocce Forbes Advogados is a large Brazilian firm spread across four national offices. The tax team consists of around 30 lawyers split between partners and associates. The tax team has strong experience involving domestic and cross-border transactions, corporate reorganisations, litigation, private equity, debt restructuring and project finance. Clients come from a variety of sectors including energy, finance, retail, wholesale, transportation, and packaging. Partner Renato Souza Coelho is a key individual at the firm.

During the research period, the firm advised Companhia de Gás de São Paulo in the filing of a tax lawsuit to request the postponement of the corporate taxation over the tax credits acknowledged by the Judiciary in several tax lawsuits to the moment in which the tax credits are available to utilization (offsetting with other taxes).

Marcos Prado left the firm to LBMF in May of 2022.

Client feedback

“Result-oriented and pragmatic firm. Excellent experience led by Renato Coelho. Trusted advisors on all projects.”

“They have a broadly view. They do not just focus on the problem/situation that I put to them for discussion. We go deply analysing the whole situation and possible solutions.”

“High quality, efficient and business oriented.”

“Very engaged in clients needs, very good deliver material, disposal to proactively attend demands.”

“They are very disruptive providing us with very good solutions with legal base.”

Tauil & Chequer's tax advisory, customs and litigation lawyers represent Brazilian and international companies in administrative (Local, State and Federal) and legal proceedings and have a prominent practice before the Brazilian Supreme Courts – STJ and STF. Through the association with Mayer Brown, clients have access to a full-service global law practice, and can offer the knowledge of both local legal and political market combined with global reach. The team is recognized as one of the leading tax law firms in Brazil in the oil & gas sector and telecommunications.

During the research period, the firm in consortium with Banco Genial, won a competitive bidding procedure carried out by BNDES to provide legal assistance within the scope of the privatization of Eletrobrás. The work included the elaboration of a legal mapping report, modelling report and a modelling proposal for deliberation of Eletrobrás. The team worked on the tax aspects of the deal structure and the post steps involved such as the tax aspects of the “direito de recesso“and capital gains of the investors that withdraws from the shareholders position.

Partner Thais Rezende left the firm in March of 2022 to Mattos Filho. The firm welcomed  as counsel, previously from the Brazilian Federal Administrative Tax Court (CARF).

Client feedback

“Most notably the responsiveness and business insights.”

“Knowledgeable, proactivity, thinking out of the box, adaptability.”

Terciotti Andrade Gomes Donato Advogados was founded in 2014 by experienced professionals mainly focused on the tax area (advisory and litigation). In the following years the firm started expanding its range of activities to other areas, in practices such as corporate, energy and dispute resolution. Clients are from a wide range of sectors and our professionals have a solid experience in the most various industries, with special focus on telecom, mining, energy, commerce, service providers, engineering, agribusiness, oil and gas, and shipping.

During the research cycle, the firm assisted Centrais Elétricas do Norte do Brasil in a lawsuit aimed at the reimbursement of the Social Security Contributions on the Gross Revenue (PIS and COFINS). Partners got the decisions revoking the injunction days before the deadline to exclude/exempt the PIS/COFINS of the month.

The firm recruited two associates previously from Miguez de Mello Advogados: Alexandre Ribeiro and Jonatan Amorim.

Client feedback

“The law firm is equipped with a group of exceptionally skilled attorneys who have a deep understanding of tax law. Their suggested legal tactics are outstanding and instill confidence in clients. The team is readily accessible to provide swift and efficient services, showing a strong commitment to meeting clients' needs. The work delivered  is of the utmost excellence, showcasing their exceptional abilities and expertise. Moreover, their exceptional communication skills and attentiveness to clients' needs establish them as a dependable and trustworthy choice for tax law-related legal services.”

“The office is always up to date, providing the best services, with agility and competence.”

Tilkian, Marinelli, Marrey Sociedade de Advogados assists large, and medium size taxpayers. The firm’s work includes auditing procedures, consultations, and the conduct of disputes between our clients and the fiscal authorities. Its tax practice in focused on tax advisory, administrative litigation and judicial litigation.

During the past year the TMM tax team represented the interests of Dolly Brazil Refrigerantes and other affiliated companies of Dolly’s group in a tax precautionary measure filed by the Brazilian National Treasury. Furthermore, it has been proved that the debt is a result of multiple frauds committed by a former account office, as well as major part of the value consists in an unlawful charge by the Brazilian IRS. This case represents a major role in Dolly’s economic activity, given the company market share in beverages sector and the risk that is imposed by a potential tax enforcement.

Established in 1976, TozziniFreire Advogados is a reputable full-service law firm with seven offices in Brazil. Its tax team is made up of ten partners and over 60 professionals. It is active in numerous sectors such as agribusiness, telecommunications, IT, energy, oil and gas, retail, pharmaceutical and logistics. Its main practice areas include tax controversy, general corporate tax, and transactional tax, with an emphasis on M&A and cross-border transactions. The firm’s tax department is headed by Gustavo Nygaard and Renata Emery.

TozziniFreire has continued to represent Rumo Malha Norte in a tax litigation case that challenges the Federal tax authority’s assessment due to the misuse of PIS and COFINS tax credits over expenses related to railway infrastructure. If the courts recognize the PIS and COFINS credits over these expenses, the case will likely impact the transport sector, since a huge value of tax credits of PIS and COFINS would be granted to railway companies operating in Brazil.

Partner Vinícius Jucá left for Lefosse Advogados in May of 2022. However, the firm welcomed two new partners, Alberto Medeiros and Bruno Rodrigues Teixeira de Lima.

Client feedback

“Excellent organization, communication, documentation and support.”

TPC Advogados is located in Belo Horizonte. The team provides multidisciplinary analysis and a broad view of business, with extensive expertise in tax consulting and litigation. Consultancy services include the elaboration of legal opinions and reports for tax risk analysis, benefits, and viable alternatives. In tax litigation, the firm is active in both administrative and judicial spheres, assisting clients in litigation involving federal, state, and municipal taxes. The firm consists of one partner and four associates.

During the research cycle, the firm represented Jamef Transportes Eireli. It filed a lawsuit seeking seeking the exclusion of indemnity payments from the calculation basis of social security contributions, such as notice of termination, one-third holiday premium, and holiday pay, among other amounts. Success from the lawsuit may generate large savings for the company.

Treiger Grupenmacher Advogados Associados was founded in 1988 by Professor Doctor, Betina Treiger Grupenmacher. The firm is headquartered in Curitiba and seeks to provide legal protection to companies and individuals. It is specialized in the sales sector, industry, computing, marketplace, and transportation, but have clients in every sector.

The details of the case details and clients are to remain confidential.

Junior partner Matheus Ziccarelli departed to become an administrative judge. Associate Roberta Wink also departed the firm in July of 2022. However, the firm welcomed new associate Michele Giamberardino Fabri, previously from Moro Domingos e Marcovici Advogados Associados and junior partner Flávia Treiger Grupenmacher, previously from Arruda Alvim, Aragão Lins e Sato.

Trench Rossi Watanabe is a firm specialized in all areas of tax with tax litigation as one of its most important practices. The firm also has expertise in international taxation. This expertise is further supported by their relationship to Baker McKenzie, which allows the firm to provide global tax solutions to Brazilian multinationals that are acquiring businesses and starting to invest abroad. The team assists different industry sectors, Automotive, Oil & Gas, Technology, Consumer Goods, Healthcare, Banking & Finance and Infrastructure.

During the research period, the firm advised Croplife Brasil with the purpose of intervening as amicus curiae in a lawsuit filed by a political party - The Socialism and Freedom Party - before the Federal Supreme Court (ADI n. 5.553/DF). This case is a leading case that discusses the constitutionality of federal regulations that grant tax benefit/relief for agrichemicals/agriculture defensives, as part of Brazil's fiscal policy created to aid, boost, foster and promote production and competitiveness for the agricultural sector.

The firm promoted two senior associates: Beatriz Almada Nobre de Mello and Marcelle Silbiger de Stefano. Additionally, it promoted Telírio Saraiva to partner.

Client feedback

“Because of the professionals.”

“Adriana Stamato and Rafael Gregorin, who are tax partner, are excellent lawyers.”

“Baker Mckenzie (Trench Rossi Watanabe), especially Maria Rita Ferragut, provides the best and most up to date trends on tax litigation, providing strategy and a tailored analysis for our business.”

Trouw e Fraga Advogados is a boutique law firm which advises on all tax fields. Among the firm’s clients are players in the oil and gas, telecom, and pharmaceutical industries.

During the research period, the firm represented TIM before the São Paulo Municipality. The matter has not yet been judged by the Courts and involves high economic values to the Company. Details from other cases are confidential.

The firm welcomed partner, Rodrigo Damázio de Miranda Ferreira, previously from Demarest.

Client feedback

“Very good law firm; good prices, excellent lawyers, always available to discuss tax topics.”

“Proactive, highly technical and easy-going.”

“Trow & Fraga Advogado's expertise on the field plus a very proactive approach allowed us to find strong opportunities to improve our tax planning.”

“Clarity to explain the legal situation, proposal of appropriate action plans, availability to be served as clients, analysis capacity and speed of response.”

“Deep knowledge of the market in general and specially in local taxation with high complexity. Speed of reply and accuracy on their suggestions.”

In the tax practice of Urbano Vitalino Advogados, it acts preventively upon preparing legal opinions and tax-efficient legal structures for corporate, estate and succession matters. In M&A transactions, the tax team participates in due diligence procedures to provide a comprehensive legal review of tax assets and liabilities related to target entities.

During the past year the team was hired by various clients to act on behalf of its legal defense. An example, the tax team was hired by the client (confidential), a major environmental company to file a defense from a charge from the government (Municipal taxes).

Client feedback

“Very deep tax knowledge by the Partner Fábio Lemos Cury who has a clear and functional communication that understand the business challenges and provides the best solutions with creativity and tax compliance taking to account the bussiness results.”

“The Urbano Vitalino Advogados´s attendance is very professional, available, carefullness and precise.”

Utumi Advogados is a highly prestigious boutique firm that advises on international taxation for Brazilian and multinational companies, as well as high net worth families. It has a solid background in the taxation of complex mergers and acquisitions, corporate restructurings, transactions in the financial and capital markets, international trade (import/export), indirect taxes and international taxation. Among the industry sectors the team advises, there are telecommunications, IT, energy, food & beverage, pharmaceutical, automotive, consumer products, retail, and mining. The team also has expertise in the taxation of high-net-worth individuals and families, succession planning and asset planning.

The tax team performed a tax analysis for Leonardo, involving the possible alternatives to an Italian consortium, which our client is a member, to participate in a public bidding, which aims to acquire between 98 and 221 armed vehicles to the Ministry of Defense.

Client feedback

“Utumi is a boutique Tax Firm, which is lead by Ana Claudia Utumi, who is a female leader in the tax area and a reference in the tax field, specially on international tax matters. Camila Tapias is another prominent tax partner, with a lot of expertise under her belt.”

VBSO Advogados advises in many different tax areas, with a focus on general corporate tax and tax controversy. The team represents its clients before municipal, state, and federal courts. The firm is especially active in matters related to the corporate income tax (IRPJ), social contribution on net profits (CSLL) and social contributions on revenue (PIS and COFINS). Recently, the firm has collected favorable decisions for its clients from the electric power sector.

Details of the firm’s cases are confidential.

Senior associate Davi Finotti Ferreira departed to FLH Advogados in October of 2022.

Client feedback

“Great new firm. Excellent team.”

“The most positive attribute is the technical skills.”

VBD Advogados’ tax division is responsible for advising clients on different tax matters, such as M&A operations, corporate reorganization, tax planning and legal opinions.

During the research period the firm advised BMB Material de Construção. VBD was then hired to assist both in evaluation and suggestion of more efficient real estate legal structures from the tax perspective, so that the company would not be subject to the high rates of real estate funds at the initial moment of stores expansion, as well as would not face possible tax inefficiency in the operation in case of financing the construction of stores under expansion for later leasing ("sale/leaseback" model).

Partner Isabella Müller Lins de Albuquerque left to pursue a solo practice in August of 2022, however, the firm welcomed new partner, Leonardo Freitas de Moraes e Castro, previously from Bueno & Castro Tax Lawyers.

Veirano Advogados has four offices in São Paulo, Rio de Janeiro, Brasilia, and Porto Alegre. The team of 12 partners, one counsel, and 32 associates is fully dedicated to litigation, tax advisory and planning, customs, and international taxation. The team works with a variety of industries, such as Energy, Entertainment, Telecom, Mining, P&E and M&A, Tobacco, Vehicle Tracking Services, Electronics, Oil & Gas, Construction, Sugar/Ethanol, Food, Beverages, Water/Sewage, Petrochemical, Automobiles, IT, Forestry and Paper, Shipbuilding, Defense, Software, Insurance and Healthcare.

During the research period the firm advised BSBios and shareholders in the review of all tax aspects associated with the inversion of the company to Switzerland.

Vieira Rezende Advogados’ team has an expertise in tax litigation and represent its clients before all Brazilian courts, specially the State and Federal Administrative Courts, State and Federal Courts, Superior Court of Justice, and the Federal Supreme Court. The team of five partners and more than 15 associate and defends clients mostly in the areas of Oil, Gas & Offshore and Metals, Engineering, Infrastructure & Logistic Systems; Finance; Agribusiness, Education, Insurance/Private Health Plans; Pension Funds and Retail & Commerce.

Vieira Rezende’s tax team assisted Samarco in analyzing and suggesting alternatives to settle the outstanding debts, as well as related tax contingencies and risks, mainly from an international perspective. It also prepared legal opinions and participated in meetings with the company’s financing and legal counsel and with Samarco’ s shareholders and respective internal and external counsels.

The team promoted Bruna Luppi to partner from senior associate January of 2022.

Client feedback

“They are proactive, very smart in the strategies of the processes and their answers are always according to our business (they know us).”

“Office with highly qualified professionals, support and quick turnaround.”

“Veirano has technically highly qualified professionals for the areas that demand more attention for Mars. They understand the demands very well and provide adequate direction for high quality defenses.”

“Expertise and commitment in the all tasks about process defense.”

Viseu Advogados tax team advises on all tax matter and is particularly focused in M&A transactions, litigation, due diligences, and restructuring, as well as general corporate tax consulting. The firm works with a variety of sectors, including oil and gas, perfumes and cosmetics, education, industry, civil construction, technology, automotive, wholesale, finance services and health care.

During the research period, the firm worked with Whirpool Corporation. It worked on behalf of the clients before the Court of Justice, being responsible for unprecedented cases within the tax area, especially regarding the VAT Tax Substitution (ICMS-ST).

Partner Fábio Nieves departed to Fábio Nieves Advocacia Tributária. However the firm welcomed two new partners: Priscila Farisco from Mattos Engelberg Advogados and Guilherme Manier Monteiro from Monteiro, Rusu.