Tax in Brazil

Sacha Calmon e Misabel Derzi Consultores e Advogados

Boutique firm Sacha Calmon e Misabel Derzi Consultores e Advogados is a leading firm in the Belo Horizonte market for strategic tax matters. The practice attracts instructions from high-profile clients active in a range of industries, including mining, construction, automobile and education. The department is adept in non-contentious domestic and international tax matters, while also fielding the ability to assist with administrative and judicial tax litigation. Recent mandates include advising on tax optimisation, new tax legislation proposed by the government and tax disputes before the superior courts in Brazil. Valter Lobato leads advice to heavyweights from the mining and steel sectors, and combines expertise in tax consulting and litigation matters. André Mendes Moreira, Juliana Junqueira Coelho and Paula Derzi lead the practice with Lobato. Fernando Moura is noted for international tax and restructuring issues.

Testimonials

‘The firm is composed of a team of highly qualified professionals, with a strong academic background. The team we deal with demonstrates differentiated knowledge and a broad view of the client’s position.’

‘Valter Lobato and Fernando Moura show a broad interest in knowing the client’s activity and, also, an exceptional technical quality. In addition, the customer relationship is extremely professional.’

‘The law firm has an unique deep knowledge in tax planning, tax consulting and tax litigation. The partners are a huge reference in the Brazilian market with strong skills to solve complex issues in a very good speed. Definitely a tier one in the market.’

‘Valter Lobato stands out in tax and tax litigation.’

Key clients

VLI Logística

L’oreal Brasil

Ambev

Huawei

CRBS

Algar Telecom

Palmyra do Brasil Indústria e Comércio de Silício Metálico e Recursos Naturais

Bravo Soluções Logísticas

Arcelormittal

Samarco Mineração

Aperam Inox America do Sul

Localiza rent a car

RIP Servicos Industriais

Thyssenkrupp Group

Atlantic Nickel

FCA Fiat Chrysler

Acesita Previdencia Privada

Work highlights

  • Assisted L’Oréal with a tax infraction notice filed by the tax authorities of the State of Minas Gerais.
  • Assisted AMBEV with a tax infraction notice filed by the tax authorities of the State of Minas Gerais.
  • Advised Huawei Do Brasil Telecomunicações on a tax infraction notice filed by the tax authorities of the State of Minas Gerais.
  • Assisted Algar Telecom with a writ of mandamus against the National Department of Transportation Infrastructure (DNIT), in order to gain access to highway domain lanes without the need to undertake payments for their use.

Fialho Salles Advogados

The tax practice at Fialho Salles Advogados offers a broad service offering, covering tax planning, tax consulting and litigation. The group is led by Marcos Ortiz, Paulo Andrade and Roberto Salles based in São Paulo, and Patrícia Lima, who oversees the Belo Horizonte tax litigation team. Lima has solid experience in the field of judicial and administrative tax litigation, as well as projects pertaining to tax efficiency. With a thorough knowledge of municipal, state and federal taxes, Leandro Vieira is another noteworthy practitioner, who stands out for tax planning and acting on behalf of clients before tax authorities. Direct and indirect taxes are core areas of focus for Pedro Magalhães.

Testimonials

‘The team knows how to work as a group. It is common for associates and partners to indicate each other depending on their tax expertise.’

‘The lawyers are very senior, listen carefully to the clients’ issues and have a good sense of urgency.’

‘Lawyers have a lot of technical knowledge, are detail oriented and committed and are always available, acting as partners.’

‘What makes lawyers in the firm stand out is their technical knowledge, the seriousness with which they deal with our issues, commitment, availability, acting as partners, always updating us on the main tax discussions (whether ours or not) and bringing new opportunities.’

‘Patrícia Lima and Leandro Vieira demonstrate professionalism and a total mastery of the analysed subjects.’

‘Dedication, seriousness and commitment to customers. Knowledge about the case.’

Key clients

Confederacao Nacional da Industria – CNI

Aperam Group

VLI Group

Hortigil Hortifruti

Drift Comércio de Alimentos

Arcelormittal

Jaguar Mining

São Marcos – Saúde e Medicina Diagnóstica

Clamper Industria e Comércio

U&M Mineracao E Construcao

BRK Ambiental Participacoes

Fundação de Desenvolvimento da Pesquisa (FUNDEP)

Work highlights

  • Represents Mineração Serras do Oeste in a lawsuit filed to enable the company to transfer its ICMS credits.

Gaia Silva Gaede Advogados

Gaia Silva Gaede Advogados offers legal support to companies doing business in Minas Gerais in relation to the entire spectrum of tax law, including consulting and judicial and administrative litigation. Department head Marcio da Rocha Medina is retained by clients from the mining, services, retail and manufacturing sectors in tax planning and contentious proceedings. Recently promoted partner Vitor Dantas Dias stands out in tax litigation, while Felipe Millard Gerken focuses on tax consultancy.

Practice head(s):

Márcio da Rocha Medina

Key clients

Kinross Brasil Mineracao

Leagold Mining Corporation

Instituto Hermes Pardini

Denso Sistemas Termicos do Brasil Sankyu

SAE Towers Brasil Torres de Transmissao

Petronas Lubrificantes BrasilTRONAS LUBRIFICANTES BRASIL S/A

Seculus da Amazonia ind Comercio

Oncoclinicas do Brasil Servicos Medicos

Supermix Concreto

EMAM Asfaltos

Unidas

Mineracao Aurizona

Organizacoes Francap

Work highlights

  • Advising Emam Emulsões e Transportes on the legal possibilities of using ICMS accumulated credit balance; state tax on the circulation of goods.
  • Acted for Seculus Da Amazonia Ind. Comercio in the correction of defects and proper direction of the judicial discussion, obtaining a sentence favourable to the company in the discussion of the reduction of the calculation basis of certain taxes.
  • Obtained a favourable ruling on behalf of Emam Emulsões e Transportes ensuring the right of the company to retrieve the undue tax payment of PIS and COFINS on internal operations taken place in the Manaus Free Trade Zone.
  • Obtained a definitive judicial decision exempting Unifort from the obligation to collect PIS and COFINS from ICMS regarding the company’s sales operations performed in the last ten years.

Rolim, Viotti & Leite Campos Advogados

Rolim, Viotti & Leite Campos Advogados is able to assist clients with the full array of tax matters, including tax planning (covering both domestic and international tax), direct and indirect tax, and tax-related advice in the context of M&A transactions and corporate restructurings. Other areas of focus include tax incentives and litigation. Alessandro Mendes Cardoso specialises in tax and customs law as well as social security matters. Luciana Goulart Ferreira and Frederico de Almeida Fonseca, whose areas of expertise include incentive programmes and optimisation procedures, are other notable partners in the team.

Vilas Boas, Lopes e Frattari Advogados

The tax department at Vilas Boas, Lopes e Frattari Advogados is adept in tax litigation at both judicial and administrative levels, with experience before several municipalities and states in Brazil. The practice is also skilled at providing legal opinions in relation to tax planning and benefits. Tax expert Rafhael Frattari leads the group.

Practice head(s):

Rafhael Frattari

Testimonials

‘I believe that their work is unique basically for two reasons: they are very committed and available. What makes lawyers in the firm stand out is the seriousness with which they deal with our issues, commitment and availability. I would like to highlight Rafael Frattari as my main contact in the law firm.’

‘The firm provides a specialised technical service that is actively and effectively monitored by a partner.’

‘The work developed by VLF is presented in a technical way and at a competitive price in relation to the local market, which gives us excellence in services provided at a low cost to the company.’

Key clients

Arcelormittal Brasil

Enecel Energia Comercialização e Consultoria Energética

CRH Sudeste Indústria de Cimentos

Banco Triângulo

CMU Comercializadora de Energia

Colégio Registral Imobiliário de Minas Gerais (CORI-MG)

Azevedo Sette Advogados

Azevedo Sette Advogados is a reference in the Minas Gerais market. In tax, the group is well equipped to assist with judicial and administrative tax litigation before municipal, state and federal authorities, and it also assists clients in the recovery of tax credits. Leandra Guimarães is the name to note in the Belo Horizonte office.

Freitas Ferraz Capuruço Braichi Riccio Advogados

The tax department at Freitas Ferraz Capuruço Braichi Riccio Advogados demonstrates specialist knowledge in international tax matters. The team has a proven track record in the development of tax structures in the context of M&A and corporate restructurings. Regular mandates also include advising clients from across the energy, real estate and fintech sectors on tax planning, which is an area of particular strength for highly regarded practice head Thiago Braichi. Júlia Barreto also receives praise.

Practice head(s):

Thiago Braichi

Testimonials

‘The firm’s partners and associates are very dedicated, have deep technical knowledge and business vision, and work to provide legal security. Thiago Braichi is extremely talented in understanding our business.’

‘The law firm is totally available and engaged. Thiago Braichi has a deep knowledge about tax and can easily explain to lawyers and non-lawyers about the matters in discussion. The quality of the tax opinions is very high and always reach the expectations of the managers.’

‘The team is very good and cohesive, they always serve in an agile manner and in record time. In addition to my view, they always present new and reliable solutions for the situation. Thiago Brachhi is a very capable individual, with a unique line of reasoning, and with great technical capacity.’

‘I would like to highlight their personalised counsel, being always available for key calls and meetings and trying to understand our legal demands in a strategic view. I would also highlight their multi-functional partners as a huge capability, especially because most of our demands requires an accounting/legal overview.’  

‘Thiago Braichi is an outstanding lawyer and accountant. His background enables him to present an excellent macro-view of our tax issues, regarding Brazilian law and accounting rules.’

‘I would like to also highlight Julia Barreto, who is an outstanding lawyer and always demonstrates her engagement in solving problems and on giving legal opinions.’

‘They are deeply committed to your company needs and aligned to your goals. They also are always available and provide first-class services.’

‘When compared to other firms, partners are very available for quick consultations and meetings. Thiago Braichi has knowledge and experience with international tax that is not easy to find in our region.’

Key clients

Biomm

BanQi (Airfox)

Canadian Solar CEI – Companhia Energ. Integrada Horizonte Minerals PLC

Motion Metrics International Corp.

Phibion PTY

América Energia

Imdex Limited

Noverde Tecnologia e Pagamento

Avenue Code Dese. e Com. SoftwareStoque Soluções Tecnológicas

Monetizze Participações

Globalbev Bebidas e Alimentos

Hekima Tecn de Gestão Dados Inte.

TORC – Terraplenagem

BII BTS Contagem 1 Participações

Patrimar Engenharia

HY Brazil

Seedz

DLM Invista Gestao de Recursos

Total Energia

CJE Empreendimentos

Work highlights

  • Advised BanQi (Airfox) on its cross-border tax structuring in relation to the partnership between Airfox, a Boston-based technology company, and Via Varejo, a major Brazilian retailer.
  • Assisted BII BTS 1 Participações in the corporate tax planning of three investments through the underwriting of securities issued by a closed-end investment fund to build and lease a logistics building.
  • Advised Hekima in an acqui-hiring process, through which iFood acquired 100% of Hekima’s equity, which involved tax planning for the sellers, among other matters.

Rodolfo Gropen Advocacia

Tax boutique Rodolfo Gropen Advocacia has established itself as a reputable player in the Minas Gerais market. On the advisory services front, the practice is proficient across indirect and consumption taxes, while also fielding the capability to advise on income tax, social security contributions and tax planning. Litigation is another strong area of activity for the team, which often acts in judicial and administrative proceedings. Tax litigation expert Rodolfo Gropen leads the department alongside managing partner João Rolla, who is experienced in tax compliance issues. Juliana Melo Ribeiro focuses on litigation and stands out for her substantial knowledge of the mining sector.

Testimonials

‘Rodolfo Gropen Advocacia is a well-established tax law firm with remarkable experience in conducting strategic cases in local and federal courts that demand highly technical expertise.’

‘Its professionals are recognised for their solid practical knowledge in a wide variety of market areas and their active participation in tax law organisations, what makes Gropen’s team very reliable to deal with matters of paramount importance.’

‘João Rolla is known for his in-depth tax knowledge and excellence in dealing with both daily tax issues of multinational and national companies and strategic litigation cases involving high figures, especially in the High Courts. He is also a distinguished leader and skillful manager whose competence is recognised by the market and peers.’

‘Our demands are fast and properly addressed. They are always willing to do more than expected. Juliana Ribeiro is excellent in tax litigation.’

‘Rodolfo Gropen Advogados is a mammoth tax law firm in Minas Gerais. However, they are able to support their clients personally, like a boutique law firm. In my opinion, this is the main characteristic – personal support – that made them completely different from others. On the other hand, they have got a great team of lawyers very specialised where you can find all best solutions to your problems just around the corner. ‘

Key clients

Vale

Nestlé

Supermercados BH

ArcellorMittal

Fiat

Anglo American Brasil

Oi

Mosaic Fertilizantes

Novelis

Tractebel

VLI Multimodal

Usiminas

Hypofarma

Belgo Bekaert

Alesat Combustíveis

EUPAR

Mineração Rio do Norte

Ligas de Alumínio – LIASA

Localiza

Aurizona

Ayres Ribeiro Advogados

The specialised tax team at Ayres Ribeiro Advogados handles matters pertaining to tax optimisation and risk assessment, as well as due diligence, infraction notices and tax litigation within the judicial and administrative spheres. The department is under the leadership of Gilberto Ayres Moreira, who combines expertise in tax litigation and consultancy. Marcelo Henrique Gonçalves Dias Corrêa focuses on non-contentious matters, while Tiago Câmara Miranda co-ordinates tax litigation work.

Practice head(s):

Gilberto Ayres Moreira

Key clients

Coca-cola Femsa

Heineken

Cenibra – Celulose Nipo-Brasileira

Companhia Industrial Cataguases

Bratus Capital

Globalbev Bebidas e Alimentos

Tenco – Shopping Centers

Empresa 1 – Volaris Brazil

Valmari Laboratórios Dermocosméticos AlmavivA do Brasil

Work highlights

  • Advised Globalbev Bebidas e Alimentos on the legal requirements for maintaining its government-granted tax benefits.
  • Assisted Companhia Industrial Cataguases in the review of all tax rules related to indirect taxes levied on its operational activities (PIS, COFINS, ICMS and IPI).

Cescon, Barrieu, Flesch & Barreto Advogados

Cescon, Barrieu, Flesch & Barreto Advogados provides tax advisory and litigation services, and has particular strength advising clients in the mining sector in connection with CFEM matters (the Brazilian mining royalty). André Alves de Melo and Renato Batiston, based in Rio de Janeiro and São Paulo respectively, oversee the tax group alongside Marcelo Mendo Gomes de Souza in Belo Horizonte. Paula Azevedo de Castro and João Raso are also active in this field.

Key clients

Kinross Brasil Mineração

Ferrous Resources

InterCement Brasil

Companhia Siderúrgica Nacional – CSN

Sul Americana de Metais – SAM

Gold X

Hipolabor

Univale

Bion

Banco de Desenvolvimento de Minas Gerais – BDMG

Work highlights

  • Provided legal advice to Ferrous Resources on mining taxation, following the creation of a tax by the Jeceaba municipality to be applied to companies that hold mining tailing dams within its limits.
  • Advised InterCement on how to avoid the illegal collection of the mining royalty on the usage of mineral resources as an input in the cement industry.

Henriques Sociedade de Advogados

Henriques Sociedade de Advogados handles non-contentious tax matters as well as judicial and administrative proceedings. Clients come from a range of sectors, including mining, energy, infrastructure and food and beverages. Tax law specialists Guilherme Henriques and Marcelo Hugo de Oliveira Campos lead the department.

Testimonials

‘The team is transparent and available.’

Key clients

Skanska Brasil

Andrade Gutierrez Engenharia

Embaré Indústrias Alimentícias

Ferrous Resources do Brasil

Cia. De Fiação e Tecidos Cedro e Cachoeira

SNEF Serviços e Montagens

OEngenharia

Odebrecht Ambiental

Omega Energia

Cristal Quality

Techint Engenharia e Construção

Localiza Rent a Car

Banco Inter

Tenco Shopping Centers

GE Power Conversion Brasil

Georadar Levantamentos Geofísicos

Consórcio Construtor Belo MonteI

SQ Brasil Instituto de Soldadura e Qualidade

S Riko Automotive Hose do Brasil

Cerne Consultoria e Projetos

BRK Ambiental

Rivelli Alimentos

Work highlights

  • Represented SNEF in a lawsuit regarding the definition of tax basis, after it was discovered that the client was overpaying social contributions on revenue (PIS/COFINS).
  • Represented OEngenharia in a charge of social contributions, after the federal revenue service issued a notice against the client because it had allegedly underpaid two social contributions (CPRB and CPFS).

Manucci Advogados

Manucci Advogados is well versed in international tax planning, and also assists clients with tax-related issues in the context of M&A transactions and investments in Brazil. Adriano Andrade Muzzi heads the tax department from São Paulo, while co-leader Gustavo Falcão in Belo Horizonte oversees all tax litigation. Litigation is also a focus for Thiago Rocha.

Key clients

Ferreira International

CBSM (Dotz)

Macrotec

Farmaconn

VMI Sistemas de Segurança

CODEMGE

Banco Mercantil do Brasil

Take

WBR Consultoria

Life Spice and Ingredients do Brasil

Work highlights

  • Obtained an urgent judicial decision that guaranteed the maintenance of Ferreira International in the differential taxation regime, ensuring the exemption of payroll and avoiding the increase of its tax burden.
  • Obtained a court decision on behalf of Macrotec, which generated a large tax reduction for the client due to a thesis that changes the understanding of the federal revenue on accumulation of taxes (PIS and COFINS).

Moura Tavares, Figueiredo, Moreira e Campos Advogados

Moura Tavares, Figueiredo, Moreira e Campos Advogados is active in the field of judicial and administrative tax litigation, and is also well versed in tax planning. The team is also sought after to advise on tax issues arising from M&A transactions. Ricardo Alves Moreira and Ismail Antonio Vieira Salles co-ordinate the group with Angelo Valladares e Souza, who specialises in tax law.