Tax Law

Most of a mid-sized company’s tax exposure does not come from aggressive planning. It comes from accumulation: a debatable tax classification maintained for years, an ancillary filing submitted with an error, a credit taken under an interpretation the tax authorities reject. By the time the assessment notice arrives, the dispute already spans five tax years, an aggravated penalty and interest exceeding the principal.

The transition to Brazil’s new consumption tax system adds a layer of uncertainty. Constitutional Amendment 132/2023 created the IBS, the CBS and the Selective Tax, and Supplementary Law 214/2025 regulated the new regime. During the transition, companies will live with two systems simultaneously — which requires revisiting long-term contracts, pricing and credit appropriation before the change fully takes effect.

Who we act for

• Companies under assessment at the federal, state or municipal level
• Companies with accumulated tax liabilities, in evaluating settlements and instalment programmes
• Companies in tax enforcement proceedings, in defence and in disputes over security
• Partners and officers added as defendants through liability-shifting
• Companies in M&A or reorganizations, in quantifying and allocating tax contingencies
• Companies with long-term contracts, in adapting to the IBS and CBS transition

How we work

We begin with an economic triage of the liabilities, not with the legal theory. Not every assessment is worth fighting: there are cases where a tax settlement (Law No. 13,988/2020) or an instalment programme produces a better result than a ten-year defence with an uncertain outcome. Only after that triage do we decide where to concentrate technical effort.

In administrative litigation, the evidentiary record built at the objection stage is decisive. Documentary evidence and expert reports not produced before the first-instance tax panel are unlikely to be accepted later — and a case that reaches CARF (the federal administrative tax appeals council) without a factual record tends to shrink into a purely legal argument, less favourable terrain for the taxpayer.

That is why we bring partner professionals from the accounting and expert-evidence fields into the case team from the objection stage, not only when the dispute reaches the courts.

Scope of work

• Administrative objections and appeals to CARF
• State and municipal administrative tax litigation
• Declaratory and annulment actions and writs of mandamus in tax matters
• Defence in tax enforcement, motions to stay and pre-enforcement objections
• Disputes over security, surety bonds and bank guarantees in tax enforcement
• Defence in liability-shifting proceedings against partners and officers (Art. 135 of the Brazilian Tax Code)
• Individual and programme-based tax settlements (Law No. 13,988/2020)
• Instalment plans and tax regularization programmes
• Recovery of overpaid taxes and credit claims
• Advisory on indirect taxation: ICMS, IPI, ISS, PIS and COFINS
• Tax succession analysis in corporate transactions (Art. 133 of the Brazilian Tax Code)
• Adaptation to the consumption tax reform (Constitutional Amendment 132/2023 and Supplementary Law 214/2025)

Related practice areas

Mergers & Acquisitions · Port and Waterway Law · Judicial Reorganization and Bankruptcy · Agricultural Law

To discuss a specific matter, please get in touch and schedule a consultation.