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Our area of ​​expertise: TAX

We are clearly committed to the practicality of the proposed solutions, considering accounting impacts on our opinions.

We seek to be authentic strategic partners of our customers and for that we focus on personal service and lasting relationships of trust.

List of Tax Consulting and Planning Cases, Tax Litigation, International Operations and Wealth Planning.

Planning and Preventive Guidance

Support for relevant decisions and day-to-day advice.


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Wealth Planning

Estate, succession and tax planning for families.


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Administrative and Judicial Litigation

sponsoring the defense of interests in tax litigation.


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International Investments

Tax advice on inbound and outbound operations.


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Tax Consulting and Planning

1. Tax architecture for road transport application: we leverage the attractiveness of the app, avoiding risks to users and making travel cheaper by 21%.
2. We prepared the tourist services intermediary business so that it could be classified as an exporter, with 33% tax savings and a clear competitive advantage.
3. We helped the installation in Brazil of a food supplement multinational, with the implementation of a new supply chain and step plan with increasing stages of local production, anticipating challenges and investments necessary to enjoy tax incentives.
4. Elimination of contingencies before going to market: we advise an EdTech venture to eliminate red flags and receive a new round of investment.
5. We advise multinational domestic products in the validation of routines, enabling a new distribution route without loss of incentives from the Manaus Free Zone.
6. We plan corporate and contractual transactions for investment in distressed assets, enabling debt restructuring with minimal tax impact.
7. Consultancy to eliminate risks and create a fund for investors in multifamily property – development and management of rental properties.
8. Elimination of contingencies before going to the market: we advise PropTech projects to eliminate red flags and receive new investment rounds.
9. Planning in favor of EdTech to simulate advantages, costs and risks related to the creation of a publishing house within the same group.
10. We advise a multinational of domestic products in the validation of credits on inputs related to the development of your labels.
11. Opinion in favor of a software developer regarding the appropriate tax regime on its revenue from licensing, with recommendations regarding accounting and contractual routines.
12. Study on tax incidences on the export of services between Latin American subsidiaries of one of the world's largest out-of-home media groups.
13. Review of the tax burden and accounting and contractual requirements for a Latin American group-controlled freelance brokerage application in Brazil.
14. Planning for restructuring a business group under recovery judicial system, with 40 entities dedicated to the manufacture, import and resale of combustion and electric vehicles.
15. Tax planning for road transport application, with simulation of gains and risks linked to creation of utility vehicle rental within the group.
16. Planning of possible takeover by professionals of turnaround control of a commodity giant – work on behalf of creditors and investment in distressed assets.
17. Review of fiscal routines for calculating and collecting municipal and federal taxes on assignment of rights and provision of services by television content producer.
18. Review and amendment of international loan agreements, for purposes of compliance with authorities exchange and tax, in favor of engineering consultancy.
19. Creation of new routines for the application of withholdings and taxes on international remittances carried out by American control car and utility company.
20. Review of alternatives for lower tax incidence on international liabilities between Brazilian and Argentine subsidiaries of an auto parts producer group.
21. Advice on upgrading import licenses for a subsidiary of american multinational of supplements food.
22. Preparation of an opinion on tax treatment to be applied to performance bonuses in the form of delivery of shares in favor of a specialist debt restructuring consultancy.
23. Advocacy in favor of legislative proposals for the use of tax assets as collateral for granting loans.
24. Tax consultancy for importer and reseller of high-value motorcycle lubricants international brand aggregate.
25. Advising a group of cosmetics companies regarding the enjoyment of benefits linked to investments in innovation.
26. Preparation of an opinion regarding the risks of supply and application of food chemicals be characterized as industrialization.
27. Advising an Israeli group for the acquisition of a medical equipment operation in Brazil, covering different tax imposition scenarios on remittances of royalties, dividends and interest and application of international treaties.
28. Legal opinion of the American controlling multinational regarding the risks involved in the recognition accounting of tax credits obtained in a judicial measure still subject to liquidation.
29. Tax planning to establish the basic operating premises of a start-up dedicated to waste management – ​​contemplating the relationships between waste generators, their collectors, recyclers and end recipients.
30. Advice on addressing tax risks and different taxes levied on real estate exchange in operations carried out by real estate developers, with or without the use of investment funds.
31. Risk assessment for medical clinics regarding their framing in tax regimes linked to ISS on professional services.
32. Opinion in favor of a television content producer regarding the possibility of framing revenues from a contract with a provider of streaming as service export.
33. Opinion on taxation levied on commercial asset securitization companies, as well as on the risks of their disqualification as a kind of abusive tax planning.
34. Opinion regarding the charge and tax base on tourist intermediation services and compliance regarding the issuance of documents by all those involved (agency, intermediary, hotel and traveller).
35. Legal opinion on the basis and rate of PIS/COFINS due by securitization companies of credits not characterized as financial, agricultural or real estate.
36. Opinion on the levy of taxes on the result arising from the appreciation of FIDC shares in the balance sheet of the shareholder investing company.
37. Preparation of an opinion in favor of an investment bank regarding the levy of IRRF on payments to amortization, settlement or redemption of FIDCs held by credit securitization companies.
38.Legal opinion regarding fiscal risk scenarios involving subscription bonus linked to performance and granted in favor of turnaround service providers with indirect participation in the issuing company.
39. Risk assessment regarding receipts from abroad for reimbursement of expenses being reclassified as services and their possible export nature.
40. Tax due diligence for the acquisition of a hearing equipment distribution network by foreign investors.
41. Advice in favor of a trade association for the identification and qualification of risks linked to the use by members of the special deposit regime in the importation of equipment doctors transitioning for maintenance, no sale.
42. Opinion on the tax qualification of activities for the development and sale of genetically modified insects modified for pest control.
43. Advising a group of individual controllers to mitigate tax risks in the operation and governance of metal treatment entities (recycling and industrialization).
44. Simulation of the tax burden and risks involved in the vehicle leasing operation and its eventual disposal by a group already operating in the intermediation of collective trips, via app.
45. Planning for the provision of transport services for small orders by group already involved in the intermediation of road trips.
46. Legal opinion in favor of a credit card company regarding the tax risks arising from a precautionary measure granted by the STF suspending the effects of LC 157 - ISS.
47. ax advice for sale of AAA towers from Asian investors to consortium of funds Brazilian real estate.
48. Planning alternative scenarios for the acquisition or exchange of used medical dental equipment, with possible reconditioning and simultaneous disposal of new models.
49. Advocacy in favor of a complementary bill affecting the taxation of the fuel sector.
50. Analysis, revision and suggestion of standardized procedures to question the non-payment of ISS in co-productions of television content, with legal grounds that these would not constitute services subject to ISS.
51. Opinion on possible levy of ISS on assignment of copyright.
52. Legal opinion in favor of a television content producer regarding the possible levy of ISS on trademark licensing.
53. Consultancy for measuring the tax burden, risks and opportunities between industrialization operations by order or lease of a manufacturing plant, in favor of a grain processor for export.
54. Legal opinion regarding the survival of a zero-rate mutual IOF benefit for an exporter that takes credit abroad, even if the liability will be transferred to the creditor and debtor end, as long as the export operations that supported the tax incentive are effectively carried out.
55. Opinion on the use of fair value adjustments and accounting and tax impacts.
56. Planning to enable the disposal of Independent Production Units (UPIs) in the context of judicial recovery, via public auction, with allocation of financial liabilities and protection against inscriptions in active debt.
57. Consultancy for the measurement of impacts on the measurement of the present value of manufacturing units, considering reports prepared in foreign currency by applying the discounted cash flow method of agricultural commodities.
58. Tax opinion on the possibility of using judicial credits to offset taxes from different species.
59. pinion on taxation levied on commercial and financial asset securitization companies.
60. Opinion on the incidence, on the shareholder, of IRRF and IRPJ/CSLL on results realized within the FIDC.
61. Opinion on the incidence of fines in different scenarios of regularization of delays and inaccuracies in EFD delivery.
62. Advice for correct tax related to accounting and calculation benefits paid by the holding company in favor of family members of the controlling partner.
63. Advising legal entities in Judicial Reorganization in the management of tax liabilities, as well as in the conduction of strategies to mitigate risks and sanctions.
64. Fiscal analysis of alternatives for the acquisition of credits through the establishment of a securitization company or FIDC.
65. Technical Coordination and the Tax Committee as advisors of a relevant association linked to the development of technological products related to health.
66. Assistance in conducting the simplification of the corporate structure in Brazil of a foreign economic group from digital media.
67. Advice to investors in the application of spontaneous reporting linked to assets abroad.
68. Advocacy for oil and gas sector group against persistent tax evasion and effects on market competitiveness.
69. Opinion on the appropriation of PIS and COFINS credits on intangible assets under development.
70. Opinion on the tax treatment of financial income earned by real estate legal entities.
71. Opinion on the possibility of offsetting IRPJ estimates and CSLL overpaid during the calculation period and time of negative balance formation.
72. Opinion on the possibility of offsetting tax credits from negative balances of IRPJ and CSLL with IRRF and INSS.
73. Advice on tax planning in a structure involving the incorporation of SCP in a company in the energy sector.
74. Due Diligence in the acquisition of a technology company in the food sector by another in the means of payment sector.
75. Analysis on the incidence of IOF-Exchange on the economic availability abroad of transfer International.
76. Analysis of the inclusion of ISS in the IRRF calculation base on remittances abroad for the remuneration of services.
77. Advising a multinational company that works in the development of software aimed at the health sector in the tax planning for the implementation of its product distribution operations in Brazil.
78. Advising an investment group on the possibility of transferring credits arising from requests for refund before the RFB.
79. Assistance to Israeli investors to create a stock option program for a venture in Brazil.
80. Advising a charity institution to take advantage of benefits arising from income tax paid by individual and corporate donors.
81. Preparation of a legal opinion on the levy of IRRF on remittances made from Brazil to Mexico for payment of commissions commissions for television content producer.
82. Advice on the analysis of the legality of requirements for taking advantage of benefits related to the deductibility of expenses incurred in the Food Worker Program.
83. Assistance in the analysis of the classification of credit card operator activity according to the list annexed to Complementary Law n. ISS 116/2003.
84. Analysis of the classification of the operation as a credit operation for the purpose of levying IOF-Credit.
85. Tax planning for the purchase and sale of a Brazilian software reseller company by residents and non-residents.
86. Preparation of legal opinion on planning involving the transfer of goods between establishments of the same owner, as well as the use of tax benefits and taxation of these subsidies.
87. Analysis of taxation on rebates agreed between financial market players for fund managers of investment.
88. Assistance in the analysis of taxation of the stock option plan to be implemented in a credit card company booming payment.
89. Review of administrative offsets and tax credit update calculations.
90. reparation of a memorandum covering the accounting and tax aspects of taxation of income and income earned by a company in the retail sector within the scope of its points program (loyalty).
91. Assistance in identifying the tax rules applicable to Fintechs.
92. Tax consultancy for a startup that offers solutions for the transport and disposal of organic waste and recyclables; We conduct various topics involving the operation, fiscal routines, as well as the use of tax benefits and incentives granted on its activities, including the opening of new lines of Business.
93. Family Office assistance in the acquisition of equity interest with pre-due diligence tax analysis and operation planning with salespeople, scoring the risks involved in the operation.
94. Advising a foreign company in understanding Brazilian tax aspects related to incentive plans with Restricted Stock Units and Stock Options.

Tax Litigation

1. Theses and Tax Radar Menu: use of dedicated software and a team of experts to map more than 150 tax theses covering income, consumption and wealth from industry, commerce and services.
2. Judgment recognizing the non-levy of ISS on provider with local activities and international customers, with savings of 5% of the invoicing.
3. Obtaining an exclusive injunction in the country to release the investment fund manager from taxes on 80% of the customer portfolio, referring to those from other municipalities.
4. Recovery of payroll taxes in favor of a textile industry conglomerate.
5. Discussion regarding the recovery of taxes on capital gains on the sale of a family-controlled company, using incentives originally from the patriarch.
6. Inheritance and gift tax recovery with respect to assets kept abroad.
7. Recovery of taxes on revenues and imports for a manufacturer of mechanical and electric bicycles.
8. Strategy architecture for questioning judicial protests related to federal debts pertaining to exclusion of installment programs, in favor of the processing industry of grains.
9.Recognition of tax credits on payroll in favor of a conglomerate of heavy civil construction and transport infrastructure.
10. Tax recovery on carpet manufacturer revenue.
11. Reimbursement of taxes on billing of a paper and cardboard packaging manufacturer.
12. Defense of thesis regarding the basis for calculating taxes on remittances to affiliates abroad, in favor of chemical conglomerate under German control.
13. Questioning the bases of social contributions and taxes on sales and profit of the retail chain of construction material.
14. Defense of collection regarding the allocation of IRPF collections in favor of the estate.
15. Questioning the basis of social contributions due on the import of goods in favor of the food industry.
16. Filing of a writ of mandamus and defense in autuation for release of goods imported by a toy manufacturer, one of the leaders in the American sector.
17. Advice for planning on the litigation of judicial theses in favor of a grain processor.
18. Preparation of action to question the exaggerated increase in IPTU and improper collection of the tax on vacant land on the coast of São Paulo.
19. Sponsorship of a judicial measure questioning the basis of IPI on the importation of goods by the pharmaceutical industry.
20. Questioning the ICMS tax base on electricity consumption by cosmetics manufacturer.
21. Due diligence on the bankruptcy estate tax process portfolio for credit recovery.
22. Defense sponsorship of a domestic products multinational in charging ICMS on its distributor of northeast region.
23. Sponsorship of tax theses in favor of the cardboard industry.
24. Assessment of risks linked to a lawsuit questioning the collection of social security contributions linked to the stock option plan of a giant in the real estate intermediation sector.
25. Sponsorship of tax theses to question the revenue and profit bases in favor of an electric bicycle manufacturer and importer.
26. Advising the association of medical equipment importers and distributors in questioning the São Paulo government tax package that reduced ICMS incentives.
27. Sponsorship of tax theses in favor of clothing manufacturer.
28. Sponsorship of tax theses in favor of a supermarket chain.
29. Sponsorship of tax theses of an engineering service provider.
30. Sponsorship of theses in favor of the agricultural industry.
31. Sponsorship of tax theses in favor of importer and distributor of hydraulic pumps.
32. Filing of a measure to guarantee a special tax regime in favor of a law firm dedicated to the real estate sector.
33. Opinion on the possibility of questioning the rules relevant to the appropriation of PIS/COFINS credits for the veterinary medical products industry.
34. Collection of administrative credits in favor of the packaging industry.
35. Advice on procedural strategy, risk assessment review and new orientation of legal arguments for North American conglomerate leader in the Real Estate market regarding the discussion of taxation of INSS employer contribution on PLR to its employees in a process already underway in the Federal Court.
36. Monitoring of inspection of ISS on professional society of journalistic services.
37. Advice for evaluation of prognosis related to the defense of assessment of ICMS Tax Rate Differential involving sale of vehicle to final consumer in another State.
38. Sponsorship of a tax thesis linked to the PIS/COFINS base for the manufacturer of cosmetics.
39. Legal entity advice on conclusion of tax transaction individual with the Attorney General's Office from the National Treasury.
40. Filing of a judicial measure to guarantee that the taxpayer has the right to include in the tax transaction instituted by the PGFN the debts previously paid in installments with the RFB under less advantageous conditions.
41. Filing of legal action for legal entity not to pay the IRPJ and CSLL on the amounts related to monetary correction and interest on late payment at the SELIC rate in the refund, compensation and refund of tax credits.
42. Sponsorship of tax theses linked to the PIS/COFINS base to exclude the ICMS Aliquot Differential and the contributions themselves.
43. Filing of measure for credit card administrator to guarantee the right to non-payment of ISS in the municipality of its headquarters in view of the change promoted by LC 157.
44. Drafting of an action for annulment of debt debit arising from non-approval of offsets, in view of the non-recognition of a negative balance of IRPJ for a company in the manufacturing and sale of heating and cooling machines.
45. Sponsorship of a tax thesis linked to the PIS/COFINS base, notably for the exclusion of ICMS-ST from the taxable base, for a drug retail chain.
46. Sponsorship of a tax thesis linked to the PIS/COFINS base, notably for the exclusion of contributions from the taxable base, for companies in the food and cosmetics sectors.
47. Filing of a measure to guarantee the non-levy of IRPJ and CSLL on the monetary correction by SELIC of tax overpayments for credit card company.
48. Sponsorship of a tax thesis linked to the PIS/COFINS base for a credit card company.
49. Sponsorship of a tax thesis linked to the PIS/COFINS base for a leader in the urban media sector.
50. Sponsorship of a tax thesis linked to the exclusion of ISS from the PIS/COFINS base for a company engaged in financial advisory and debt restructuring.
51. Sponsorship of a tax thesis linked to the exclusion of PIS/COFINS from its own foundations for a company active in financial advisory and debt restructuring.
52.Sponsorship of tax theses linked to the PIS/COFINS base for the Investment in Shares.
53. Sponsorship of a tax thesis for the exclusion of the ICMS tax rate differential from the PIS/COFINS base for the pharmaceutical industry.
54. Sponsorship of a tax thesis linked to the PIS/COFINS base for a company specialized in the request and preparation of migration documents.
55. Sponsorship of tax theses linked to the PIS/COFINS base for an electronics multinational.
56. Sponsorship of a tax thesis for the exclusion of ISS from the PIS/COFINS base for a company specialized in corporate finance advisory, focusing on mergers and acquisitions.
57. Sponsorship of tax theses linked to the PIS/COFINS base for a consulting and engineering company, a global leader in mobility and transport infrastructure.
58. Filing of measure for non-levy of PIS/COFINS on SELIC of tax evasion for retailer.
59. Filing of a measure to guarantee the non-levy of IRPJ and CSLL on the monetary correction by SELIC of tax overpayments in favor of a grain processor.
60. Filing of a measure to remove the incidence of social security contributions on indemnity funds for grain processors.
61. AFiling of a measure to ensure that an administrative request for credit restitution is considered in favor of a company specializing in corporate finance advisory, with a focus on in mergers and acquisitions.
62. Filing of a measure to guarantee the non-levy of IRPJ and CSLL on the monetary correction by SELIC of tax overpayments in favor of a textile industry group.
63. Filing of a measure to ensure the deductibility of expenses without restrictions from the CSLL calculation basis.
64. Filing of a measure to guarantee the non-levy of ICMS on the transfer of goods between establishments of the same holders located in different States.
65. Filing of a measure to guarantee the non-levy of IRPJ and CSLL on the monetary restatement by the SELIC of tax overpayments in favor of a packaging industry company.
66. Filing of a measure to guarantee the non-levy of IRPJ and CSLL on the monetary restatement by the SELIC of tax overpayments in favor of a hydraulic equipment manufacturer.
67. Filing of a measure to guarantee the non-levy of IRPJ and CSLL on the monetary restatement by the SELIC of tax overpayments in favor of industrial society in the paper and packaging sector.
68. Preparation of defense in the administrative scope for a technology company related to taxes levied on imports.
69. Administration of tax litigation for a company operating in the credit card administration.
70. Filing of a measure to guarantee the right to review an administrative request filed more than 360 days ago with the RFB.
71. Filing of a measure to guarantee the non-levy of IRPJ and CSLL on the monetary correction by SELIC of tax overpayments in favor of a fleet tracking technology company.
72. Filing of a measure to guarantee the non-levy of IRPJ and CSLL on the monetary correction by SELIC of tax overpayments in favor of a consulting and engineering company, a global leader in mobility and transport infrastructure.
73. Filing of measures to guarantee the non-levy of IRPJ and CSLL, nor PIS and COFINS on subsidies for investments granted by States.
74. Filing of a measure to ensure the inapplicability of the deduction limitation, for IRPJ and CSLL purposes, of expenses related to the PAT provided for in an infralegal act.
75. Conducting administrative defense for a leading group in the urban media sector against a tax assessment on the requirement of taxes on financial income.

Wealth Planning

1. Assistance to individuals controlling international IT consultancy, with analysis of dual tax residency, impacts of/on ex-spouses and heirs from different relationships.
2. Advising the widow of an investor regarding the regularization of assets in Brazil and abroad, for the purpose of eliminating contingencies before the tax authorities, Central Bank and third creditors.
3. Governance reorganization and asset separation with maximum tax efficiency for the controlling family of a real estate conglomerate, reconciling interests of three generations and four groups.
4. Consultancy in consensual divorce of a couple of executives in the health sector, with optimization of sharing and minimization of tax costs regarding illiquid assets.
5. Advice to different family groups regarding regularization of assets abroad, with elimination of criminal, tax and regulatory risks.
6. Succession planning for individual controlling a textile group, with plant governance conciliation industrial and reseller division between heirs and third parties.
7. Preparation and follow-up of corporate restructuring in favor of network controller family group distribution of electrical equipment and financial and real estate investor.
8. Exchange and tax compliance regarding Panamanian offshore under national control.
9. Defense of assessment against estate by alleged incorrect allocation of IRPF advances.
10. Compliance advice in Brazilian tax obligations and cost reduction arising from assets abroad, for liberal professionals.
11. Assistance to start-up founders for international planning and tax reduction on capital gains arising from investment rounds and equity vesting.
12. Estate and succession planning for entrepreneurs in the arts sector.
13. Judicial questioning of taxes on inheritance originating abroad.
14. Advice on compliance with international custodians, in favor of Brazilian investors.
15. Planning in favor of tax residents in Panama in relation to their eventual acquisition of residence Brazilian due to the fact that the return to the country was affected by COVID-19, as well as succession planning with assets in the country.
16. Advice to non-residents on account of change of movable assets resulting from succession in Brazil, as well as regularization of their registration with the local tax authorities.
17. Advice on the assessment of ITCMD and IRPF levied on donations between ultra high net worth family members, with review of the relevant accessory obligations and addressing discrepancies between grant dates and realization of rights.
18. Estate planning for receiving donations and inheritances between three generations of the same family, including sponsorship of legal measures questioning taxation of assets abroad .
19. Advice on the assessment of ITCMD and IRPF in the succession of properties subject to usufruct.
20. Advice on correct accounting and tax assessment related to benefits paid by the holding company in favor of family members of the controlling partner.
21. Assessment of risks involving capital gain in the sale of property involving divorced couple sharing before sale.
22. Advice on compliance with obligations before tax and foreign exchange authorities, with a view to receiving by succession of investments abroad.
23. Assistance in the presentation of the Definitive Departure Communication from the Country and on the necessary procedures for its correct formalization in the face of the change of domicile abroad.
24. Assistance in the Individual Income Tax Return related to stock options received abroad.
25. Assistance in the transfer of shares earned by the deceased in a stock option plan abroad to his heirs.
26. Advice for an individual in the recovery of remaining amounts after liquidation of a legal entity.
27. Advice to proptech unicorn executives to receive benefits relevant to stock options plan.
28. Advising a couple (Brazilian and Swiss spouse) for change of tax residence and acquisition of real estate properties with mixed sources of equity.
29. Advising an Israeli couple with different tax residencies to moving to the country and acquiring local assets with different sources of income.
30. Advice to Brazilians in relation to assets held abroad and until then not declared to the Brazilian tax and foreign exchange authorities.
31. Family estate planning drug retail chain controller.
32. Advising non-resident Brazilians to carry out investments in Brazil, originating in Ireland.
33. Advice for investments made by a Brazilian and Norwegian couple, residents and entrepreneurs in the United Kingdom, regarding the maintenance of a company and employees in Brazil.
34. Consultancy for investments made by an individual who is not a tax resident in Brazil, domiciled in the USA, regarding real estate located in Brazil.
35. Advice for individuals in the calculation and taxation of income arising from investments made in the outside.
36. Advising an American tax resident of Panama regarding the change of domicile to Brazil.
37. Advice for an individual residing in Brazil in the acquisition of property in the country through offshore.
38. Advising individuals who are tax resident in Brazil and the USA in the sale of equity interests held formally by their parents, tax residents in Brazil and Germany, but who actually belong to her.
39. Advising entrepreneurs in the elaboration of a more advantageous tax structure in order to optimize income and income from real estate, investments and operating company.
40. Assistance to non-residents in the regularization of tax pending before state and federal tax authorities, as well as as in assessing whether income received as a result of succession should have been taxed at the time of remittance.
41. Tax planning in favor of the executive anticipating effects and scenarios for taking advantage of possible subscription bonuses, including offshore and local equity holdings.
42. Consultancy in favor of non-residents about to move to Brazil and with stock option plan about to allow the receipt of shares from companies foreign.
43. Advising a couple of Brazilian executives in relation to assets held abroad and resulting from an incentive plan with delivery of shares of international companies.
44. Advises the individual in the calculation and collection of tax on income arising from capital gain earned on the sale of property, whose acquisition was made by the ex-spouse, who paid for the payment and financing after the couple's separation.
45. Advising individuals in the sale of valuable real estate property, the negotiation of which involves the payment/installation of tax liabilities of companies held by the seller of the property, or litigation in defense of its non-enforceability, when applicable.

International Operations

1. Opinion on behalf of a large financial institution to facilitate the structuring of an international investment vehicle with the direct participation of shareholders resident and domiciled in Brazil.
2. Advice to a multinational real estate intermediation company for short-term leases for pricing transfer, with cost reduction and new tax compliance.
3. Consultancy on royalty deductibility restrictions and intra-group know-how, tax burden and application agreement against double taxation for French multinational in the nutrition and fertilizers sector.
4. Memorandum in favor of an Asian multinational to assess local tax impacts on sharing of costs with its merchandise marketing and resale services subsidiary.
5. Support for a North American multinational of real estate and hotel leasing intermediation regarding the use of payment method company and cargo analysis in remittances to different countries.
6. Opinion in favor of a software developer regarding the appropriate tax regime on its licensing revenues, with recommendations regarding accounting and contractual routines.
7. International tax planning via Legal Opinion on taxation in the various alternatives for hiring employees abroad (in Argentina, Chile and Colombia), to provide services, either locally abroad or self-employed; either by a local individual legal entity; subsidiary of the Brazilian contracting party in each jurisdiction or through the establishment of a branch; and by contracting via third-party intermediaries locally abroad.
8. International tax planning via Legal Opinion on risks, advantages and tax consequences in the characterization of Permanent Establishment of a French company in Brazil to perform various services.
9. Analysis of the incidence of IOF-Exchange and IOF-Credit in the assignment of accounts receivable from an argentine company, by a Brazilian creditor, in favor of the head office in Germany, and regulatory and accounting issues linked to such international operation.
10. Calculation of transfer pricing rules applicable to a Brazilian cosmetics company in its exports to affiliates in Latin America and review of the procedures to be adopted in the pricing of the export of such products.
11. Assistance in the analysis of the international structure for investments abroad by residents in Brazil.
12. Analysis of the international structure of an economic group in the leather sector for the purpose of compliance with the rules Brazilian transfer pricing and corresponding calculations.