Rafael Belisário — Founding Partner, Tax Law
Founding partner of TaxUp Consultoria Tributária. Direct practice in corporate tax planning, recovery of credits, Transfer Pricing under OECD standard (Law 14,596/2023), and tax litigation. Bilingual delivery (Portuguese / English / French).
Practice overview
Rafael Belisário is the founding partner of TaxUp Consultoria Tributária, a Brazilian boutique tax firm serving local mid-market companies, foreign-controlled subsidiaries and international groups with operations in Brazil.
His practice focuses on corporate tax planning, recovery of tax credits (PIS, COFINS, ICMS, IPI), Transfer Pricing under the Brazilian OECD-aligned regime (Law 14,596/2023), tax litigation (administrative and judicial), and adaptation to the Brazilian Tax Reform 2026—2033 (CBS, IBS, Selective Tax).
He serves Brazilian companies with revenue between BRL 50 million and BRL 2 billion across multiple sectors — manufacturing, retail and e-commerce, technology and SaaS, healthcare and pharmaceuticals, agribusiness — and multinationals with headquarters abroad, providing bilingual service (Portuguese and English) for foreign founders and international CFOs.
In the boutique model of TaxUp, Rafael leads each engagement personally — from initial diagnostic to oral arguments at CARF and higher courts. No delegation to juniors, no hierarchical layers between him and the client.
Education
- Law degree — University of São Paulo (USP), Faculdade de Direito do Largo São Francisco — the most prestigious law school in Brazil;
- Dual law degree — Université Jean Moulin Lyon 3, Faculté de Droit (Lyon, France);
- Specialization in Tax Law — continuing education in Brazilian tax law and international tax (OECD framework, BEPS, Pillar 2).
Areas of expertise
Direct practice across seven integrated tax areas:
- Brazilian Tax Reform 2026—2033 — adaptation to CBS, IBS, Selective Tax and the dual-system transition;
- Recovery of tax credits — PIS/COFINS (Theme 69 STF), ICMS, ICMS-ST refund, IPI — recoverable up to 5 years retrospective;
- Corporate tax planning — corporate restructuring, holding companies, tax regime selection, succession planning;
- Transfer Pricing — OECD-aligned methodology under Law 14,596/2023 (Local File, Master File, Country-by-Country Report);
- Tax litigation — defense in tax assessments, CARF appeals, higher court litigation (STJ, STF), tax transactions with PGFN;
- Tax compliance and LGPD — SPED, EFD-Reinf, eSocial, NF-e 5.0, BEPS Action 13 reporting, LGPD compliance in tax data;
- International tax / Expanding to Brazil — foreign founders, multinational subsidiaries, Pillar 2 OECD, withholding tax, CIDE-royalties.
Languages
- Portuguese — native speaker (Brazilian Portuguese);
- English — fluent for technical practice; direct communication with foreign tax directors, CFOs and international counsel;
- French — advanced (formed at Université Jean Moulin Lyon 3).
Representative matters (illustrative)
The following are illustrative engagements typical of the partner's practice, modeled on real client scenarios but anonymized to preserve confidentiality:
- Manufacturing — PIS/COFINS recovery (Theme 69 STF): recovery of PIS/COFINS via exclusion of ICMS from the calculation base, with full technical analysis of the last 5 fiscal years for a consumer goods manufacturer;
- Multinational with foreign parent — Transfer Pricing OECD adaptation: Local File preparation, FAR analysis, and method justification under Law 14,596/2023 for intercompany operations covering goods imports and brand royalty payments;
- Family group — Asset holding structure: corporate restructuring with property contribution to a holding company, ITBI immunity analysis (Brazilian Federal Constitution Article 156 §2 I), governance design for succession;
- Multi-state retail — Tax Reform impact modeling: quantitative modeling of Reform impact, Decision Simples 2027 analysis (whether to remain in simplified regime or migrate to full IBS/CBS).
Specific client identification is provided only after explicit written authorization, in accordance with professional confidentiality obligations under Brazilian Bar Association rules.
Professional affiliations
- OAB / Brazilian Bar Association — São Paulo Section, member in good standing;
- IBDT / Brazilian Institute of Tax Law — affiliated member, participation in technical committees;
- ABDF / Brazilian Association of Financial Law — affiliated.
Cross-web profiles:
How to engage
The fastest path to start a conversation is to book a free 30-minute diagnostic — a direct meeting with Rafael (or another senior partner depending on availability) to map your tax situation, identify applicable opportunities, and indicate the technical path forward.
For media inquiries, professional partnerships or speaking engagements, contact contact@taxup.com.br.
Frequently asked questions
In what language are deliverables provided?
For Brazilian clients, deliverables are in Portuguese (official version for Brazilian tax authorities). For foreign-controlled subsidiaries and international groups, deliverables are produced bilingually — Portuguese (official version, retained for Brazilian regulatory compliance) and English (working version for headquarters and international stakeholders). French is available on request for specific cases.
Does the partner personally handle each engagement?
Yes — that is the core of the boutique model. The same partner who scopes the matter at the initial diagnostic conducts the engagement personally through final delivery, including drafting the opinion, defending the structure in CARF, and oral arguments at higher courts. No work is delegated to junior associates without partner review and signoff.
How does the partner coordinate with international tax advisors?
For multinational engagements, coordination with foreign tax advisors (US, EU, Asia) follows OECD standard — Local File and Master File aligned with home jurisdiction expectations, conference calls bilingual when needed, technical opinions cross-referenced with home jurisdiction tax rules. The partner has direct experience coordinating with Big 4 international teams and local tax counsel in multiple jurisdictions.
What is the partner's position on aggressive tax planning?
The firm does not operate in the space of aggressive or dissimulated tax planning. Every elisive structure is built with three principles: business purpose (the operation must make economic sense beyond tax savings), economic substance (legal acts must reflect economic reality), and contemporaneous documentation (minutes, independent opinions, viability studies). Structures that fail these tests are not delivered. The firm is explicit with clients who want a different path that we are not the right fit.
Is there in-person availability for international clients visiting Brazil?
Yes — in-person meetings are available at any of TaxUp's three offices (São Paulo headquarters, Rio de Janeiro, Brasília) with prior scheduling. Foreign delegations are welcome, particularly when there is value in physical site visits to a Brazilian subsidiary being structured. Schedule via the booking form so we can coordinate availability and prepare materials.