The tax practice area at PVG is active both in preventive guidance and in administrative and judicial litigation of tax issues in general, especially complex ones. We provide consultancy in connection with Federal, State and Municipal taxes, be they in daily operations or in critical situations, such as the implementation of new businesses, corporate reorganizations or strategic contract negotiations. We know that understanding the client’s business is as crucial as the legal expertise, and are thus committed to identifying, quantifying and qualifying tax risks and opportunities, always aware of the integration with other areas of law. Whether in our legal opinions or in our defenses in administrative or judicial proceedings, we propose solutions and strategies based on extended technical experience, which is updated daily through the study of legislative changes and recent precedents. We work for international and national clients from the most diverse sectors and the most varied phases of corporate development, from start-ups to multinationals, from industrial companies to financial institutions.

  • Continuous monitoring of the client’s operations in order to resolve doubts with regards to the application of legislation involving Federal, State and Municipal taxes, specially income tax, social contribution on profits, PIS contribution, COFINS contribution, CIDE contribution, value-added taxes (ICMS), services taxes (ISS), tax on industrialized products (IPI), customs taxation and social security contributions.
  • Consultancy on financial and capital markets taxation, Federal and State tax benefits, tariff treatment, international agreements against double taxation, customs valuation and special customs systems, tax classification, transfer pricing and pension compensation plans.
  • Conducting of tax reviews to identify and maximize utilization of tax credits and eliminate or reduce possible contingencies, including simulations of corporate tax regimes.
  • Preparation and issuance of legal opinions based on tax legislation and its most complete interpretation taking into consideration the current scholars’ opinions and litigation precedents, so as to assist clients in strategic decision making and to provide legal support to the work of independent auditors.
  • Presentations and training on tax topics.
  • Definition of models for the development of projects in Brazil, presentation and implementation of solutions to minimize the tax burden through corporate restructuring and contractual/operational adaptations, including in international matters.
  • Support to the corporate and acquisitions practice area at PVG in the tax analysis necessary for the proposal of corporate and financing structures for mergers and acquisitions, involving local and international financial transactions, setting up of corporate vehicles and corporate and asset restructuring.
  • Conducting of due diligences to identify, quantify and qualify tax assets and liabilities.
  • Assessment and recommendations regarding tax impacts on financial products and their distribution, structuring of foreign and securities investments.
  • Preparation and negotiations regarding special tax regime requests with Municipal and State treasury authorities.
  • Consultancy on estate and succession planning for families
  • Assistance in complying with tax inspections.
  • Conducting of administrative defenses, including guidance to clients from the beginning until the end, as well as oral arguments.
  • Defense in administrative tax set-off requests which may have not been approved by the Brazilian Internal Revenue Service.
  • Consultation procedures with tax authorities so as to obtain an official position in connection with the interpretation of tax laws.
  • Pre-litigation assistance in the preparation of strategies for restitution of taxes and/or reduction of the current tax burden.
  • Promotion of legal measures in order to defend taxpayers against collection of taxes.
  • Representation of clients in tax litigation before all levels of the Judiciary, with the objective of recovering taxes collected improperly and/or obtaining a reduction of the tax exposure through the discussion of legality of laws of the Municipal, State and Federal spheres.
  • Assistance to companies on the pricing of assets and contingencies regarding ongoing lawsuits, also within the context of corporate transactions and due diligence.
  • Monitoring of precedents and lawsuits in State, Federal and superior courts in the interest of entities and class associations.