With complex legislation and a sophisticated inspection system, Brazil imposes challenges on companies in the analysis of the fiscal effects of their operations, the strategic decisions on tax disputes, and the legal certainty of taxation regimes that benefit their business.
We have initiative, creativity and solid professional experience to provide consulting and litigation advice in relation to the full range of tax issues affecting companies. We adopt a simple approach to highly complex problems, involving both sophisticated corporate and financial transactions and strategic tax litigation.
We know that changes in the rules may bring negative surprises even to organizations with large tax departments. Therefore, we adopt a proactive approach that helps companies to anticipate and reduce their risk exposure.
We provide advice on the interpretation and application of tax rules in all spheres of the public administration. With an office in Brasilia, we have a significant presence in high judicial and administrative courts and follow the leading cases related to the main tax issues under discussion in them.
Our close interaction with other office areas such as corporate, capital markets, banking, labor and real estate, allows us to provide tax advice with a multidisciplinary bias, a thorough understanding of the client's business, considering all legal and economic impacts that a particular action, aimed at resolving tax issues, can bring to the client.
We also have a team of professionals with academic and professional experience abroad that allows us to understand international tax issues and their effects on the structuring of transactions. Our experience working in cross-border operations, alongside top law firms in several countries, places us in a prime position to also offer our clients a business network and alliances developed over the years. This experience and our network of contacts allow us to work in international deals, foreign investments in Brazil, and transactions of Brazilian companies aiming to expand their business overseas.
We provide support to our clients on issues such as structuring of new projects and financial operations, customs regulations, transfer pricing, direct and indirect taxes, interpretation of international treaties, obtaining of tax incentives, and taxation of expatriates.
Our work is divided into the following areas:
- Tax planning
- Advice on structuring, reviewing the terms of, and implementing mergers and acquisitions.
- Support for mapping and analyzing different tax models to be adopted in infrastructure projects.
- Advice to foreigners who intend to start operating in Brazil.
- Analysis of the financial market from a tax point of view, identifying the best path to follow for each type of operation.
- Monitoring tax inspections and representing clients in their defense at the administrative level.
- Risk assessment of questions raised by the tax authorities and how to prepare for litigation with them.
- Consulting on cross-border transactions, multilateral treaties and interaction with foreign law firms.
- Issuance of memoranda regarding the interpretation of new laws.
- Close monitoring of decisions handed down by the courts so as to understand the position adopted in cases not conducted by Machado Meyer.
- Guidance on problems to evidence or regularize tax issues and possible tax liabilities.
- Due diligence in mergers and acquisitions.
- Advice on collective actions.