Tax
Our professionals have recognized expertise in issues related to international taxation and the application of Transfer Pricing legislation. In addition, an important part of our professionals, with double academic background and international experience, have important ability to dialogue with foreign counterparties, which facilitates and adds value in understanding the Brazilian tax legislation from the perspective of other jurisdictions and in supporting the business strategies adopted by our regional or global clients.
Our legal solutions include the preparation of memos, legal opinions, and litigation in case of taxation arising from international business, transactions, and contracts, including, in a cross-border perspective, the analysis and review of the tax consequences from corporate reorganizations, mergers and acquisitions, capital market operations, supply chain structures, and international trade (goods, services and intangibles).
In addition, we have relevant experience in analyzing and applying the provisions contained in the treaties signed between Brazil and other countries to avoid double taxation in matters of income tax, as well as in relation to the so-called “CFC Rules”, applicable to Brazilian multinational companies.
From the perspective of the Transfer Pricing legislation, we offer a full package of solutions, from the review of procedures (import, export, commodities, and interest) to the analysis and review of the value chain.
Our Firm monitors the most relevant international tax trends, including those from the Organization for Economic Cooperation and Development (OECD), to anticipate tax movements in Brazil, as well as to assess any Brazilian impacts arising from relevant tax changes abroad. For this purpose, we take advantage of our vast network of foreign professional and international firms.