Practice Area

Tax Consulting

Assistance to legal entities regarding direct and indirect taxes, social-security contributions, as well as ancillary tax obligations, in the company’s daily and extraordinary businesses. Drafting and follow-up of administrative inquiries about interpretation and application of tax legislation, and also Requests for Special Tax Treatment. Legal advice on compliance with tax audit.

Legal tax planning in the structuring of operating activity and/or asset or equity interest disposition so as to achieve the best tax efficiency legally possible. 

Legal counseling and assistance to individuals regarding Estate and Gift Tax (ITCMD) and Income Tax (IRPF), including the preparation and/or revision of the Gift Declaration, Income Tax Return, Declaration of Brazilian Capital Abroad, Final Estate Income Tax Return, and Declaration of Definitive Exit from the Country (write-off of the Brazilian Tax Residence when moving abroad). 

Practice Area

Tax Litigation

Defense of individuals’ and legal entities’ interests in administrative and judicial proceedings in federal, state and municipal levels concerning all sorts of tax and social-securtity contribution and administrative fines, including the consultation with the tax authorities.

Within the administrative sphere, legal representation provides (i) assistance in tax audit proceedings, (ii) defense against assessment or deficiency notice, (iii) drafting of requests for tax refunds, reimbursement, compensation and tax consultation, (iv) support in the formalization of settlements with government tax authorities, such as payment in installments, program of tax reduction and settlement, including counseling in leniency agreement with tax repercussion, among other proceedings inherent to the aforementioned area of practice.

Within the judicial sphere, our legal representation provides (i) defense in tax foreclosure and tax preliminary injunction, (ii) filing of suits for the reduction of the tax and social contribution burden, for the recovery of overpaid taxes, for the cancelation of administrative decision on tax enforceability, for the clearing of imported products, for obtaining clearance certificates on tax matters, for cancelling undue registration in credit reporting agencies, for securing the right of installment payment, settlement or tax reduction program, among other requests inherent to the area of practice.

Both in administrative and court proceedings, legal representation is offered upon the personal follow-up of suits and oral arguments before any administrative and judicial courts in Brazil, such as the Administrative Tax Appeals Board – CARF, the Court of Taxes and Charges in São Paulo – TIT/SP, the São Paulo Municipal Council on Taxes – CMT, the State Courts of Appeal – TJ, the Circuit Courts of Appeals – TRF, the Superior Court of Justice – STJ, and the Supreme Court of Justice – STF.


Latest Reports

Permuta Imobiliária – Lucro Presumido

Despacho PGFN 167 dispensa os procuradores da União federal a apresentar contestação, contrarrazões e recursos em ações que versem sobre a exigência do IRPJ, da CSLL, do PIS e da COFINS em operações de permuta, sem parcela complementar em dinheiro (torna), realizadas por empresas optantes pelo regime do Lucro Presumido e que tenham atividade imobiliária

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