Tax Law
Our tax practice focuses on providing advisory and litigation services to our clients, always supporting their diverse decision-making processes.
With a solid academic background, we offer our clients a broad and in-depth understanding of all tax-related matters under analysis, not only identifying opportunities but also assessing the risks involved in each situation.
The main services provided in this area are described below:
• Tax litigation.
• Legal opinions.
• Strategic and emergency tax planning.
• Tax recovery.
• Tax settlement and fiscal recovery plans.
• Tax litigation
In the contentious field, we prepare administrative defenses for our clients arising from municipal, state, and federal tax assessments, aiming to annul or mitigate the effects of such assessments, always employing the best applicable legal strategies to the specific case.
Similarly, we handle judicial proceedings, particularly in tax execution actions, actions to annul tax debts, precautionary tax measures, among others.
• Legal Opinions
We provide opinions on any tax-related issues in accordance with the current legislation and jurisprudence of our administrative and judicial courts, aiming to assist the company’s management in making decisions and to prevent future conflicts with tax authorities.
• Strategic and Emergency Tax Plan
We develop this kind of plan in situations of economic difficulty, often caused by external factors such as forced succession, reckless management, or legal uncertainties arising from legislative changes or repetitive Higher Courts’ decisions, for example.
The developed strategy involves an initial 360º analysis of all risks, alternatives, and tax instruments available and capable of implementation.
Tax due diligence, identification of contingencies, opportunities, and procedures are part of the diagnosis that leads us to the development of the short, medium, and long-term Strategic and Emergency Tax Plan, which should not be confused with what is commonly referred to as tax liability management or tax planning.
• Fiscal Recovery Plans
We are pioneers in Brazil in the development of Fiscal Recovery Plans, which are an essential and mandatory support for the implementation of an Individual Tax Settlement proposed by the taxpayer, Legal Procedural Agreement, and Judicial Recovery Plans.
Our plans include tax, accounting, financial, economic, commercial, and asset analyses, as well as the classification (rating) of the company’s tax liabilities. These analyses serve as the basis for negotiations with the National Treasury Attorney General’s Office and the Brazilian Federal Revenue Service, when necessary.
• Tax Recovery
Through a thorough analysis of the entire operation and the tax regime adopted by our client, we identify if there are any legal and risk-free opportunities for recovering improperly paid taxes, thereby increasing the company’s cash flow.
We take all administrative and judicial measures to ensure the right to credit, whether through tax offsetting, cash refunds, or even the issuance of court orders.
• Tax Transaction
Tax Transaction has become one of the main fiscal adjustment tools for companies that truly wish to address their federal tax liabilities and, in this way, achieve tax compliance as well.
It is a method of extinguishing tax credits provided for in the National Tax Code, implemented by Law No. 13,988/2020 and regulated by PGFN (National Treasury Attorney General’s Office) Ordinances.
We are pioneers in this field, particularly in the INDIVIDUAL TRANSACTION MODE PROPOSED BY THE TAXPAYER.
We negotiate directly with the National Treasury Attorney General’s Office for tax debts already enrolled or not in active debt, including those in the execution phase, with discounts, extended payment terms, and the use of other legal instruments that allow for debt reduction and settlement, particularly tax credits, court-ordered payments, and credits related to tax losses and negative taxable income of the Social Contribution on Net Income (CSLL), in the calculation of Corporate Income Tax.