Solutions

Nine practice areas, documented in English.

The nine technical fronts the firm documents in English — from the border to the higher courts. Each with its own depth, and together covering the full corporate tax cycle of a Brazilian operation, for foreign founders, multinationals and Brazilian groups operating abroad.

IBS, CBS, Selective Tax

Brazilian Tax Reform 2026—2033

Corporate adaptation to the Brazilian tax reform — IBS, CBS, the Selective Tax and the transition to the dual VAT system in 2033.

Read the practice area Law 14,596/2023

Transfer Pricing under the OECD standard

Full OECD standard since January 2024: FAR analysis, method selection (CUP, RPM, CPM, TNMM, PSM), Local File, Master File and Country-by-Country Report.

Read the practice area PIS, COFINS, ICMS, IPI

Recovery of Tax Credits

Digital tax audit of PIS, COFINS, ICMS and IPI across the last five financial years, including theses already consolidated at the STF and the STJ.

Read the practice area Pillar 2, WHT, CIDE-royalties

International Tax Planning

Multinationals and foreign founders in Brazil: Pillar 2 (Law 15,079/2024), the 10% withholding tax on dividends, CIDE-royalties and double tax treaty relief.

Read the practice area Regime, holding, succession

Tax Planning

Corporate regime choice (Lucro Real, Lucro Presumido, Simples Nacional), holding structures, JCP versus dividends and succession planning.

Read the practice area CARF, STJ, STF

Tax Litigation

Defense in tax assessments, CARF appeals, writ of mandamus and special appeals — the administrative track and the judicial track, chosen on the merits.

Read the practice area SPED, eSocial, DCTFWeb

Tax Compliance

The SPED ecosystem end to end: eSocial, EFD-Reinf, ECD, ECF, DCTFWeb and the NF-e layout of the reform (NT 2025.002).

Read the practice area Import taxes, drawback, DUIMP

Customs Law and Foreign Trade

Import and export with legal certainty: the five import taxes, drawback, ex-tariff, RADAR, AEO, DUIMP and defense against forfeiture penalties.

Read the practice area Advisory and litigation

Tax Lawyer in Brazil

Tax law for companies operating in Brazil with a senior lawyer running every case — from the planning stage to oral argument at CARF and the courts.

Read the practice area Inbound brief

Expanding to Brazil — the founder brief

What changes for a foreign group setting up in Brazil in 2026: withholding on dividends, Pillar 2, the reform and the real compliance load.

Read the practice area

How the practice areas connect

The fronts are not compartments. A typical engagement for a mid-size or large company runs three to five of them in parallel:

Tax reform + credit recovery — modelling the IBS/CBS impact on future margin is more robust when done alongside the recovery of PIS/COFINS credits from the last five years. Both analyses read the same SPED and EFD-Contribuições files, and the recovery partially funds the adaptation project.
Planning + transfer pricing — for multinationals and groups expanding abroad, the Brazilian corporate structure has to be designed against the full OECD transfer pricing regime (Law 14,596/2023) and the 10% withholding tax on dividends in force since 2026.
Litigation + compliance — a tax assessment usually exposes a compliance gap that deserves a systemic fix. Winning the argument is not enough; the internal control has to change so the exposure does not recur.
International planning as a cross-cutting layer — for foreign founders and multinationals, the international front articulates the other eight with the tax perspective of the parent company, under OECD standards and the treaty network.

The usual entry point is the free 30-minute tax diagnostic with a senior consultant, where we map which fronts are material for the specific operation.

Free 30-minute tax diagnostic

A direct conversation with a senior consultant, in English. We map the applicable exposures and opportunities and point to the most sustainable technical path — whether or not you continue with us.

Book the diagnostic

Perguntas frequentes

Frequently asked questions about
our seven practice areas.

What foreign CFOs and tax directors ask before the first call.

Where should a company start with the Brazilian tax reform?

With a diagnostic of what changes in its own operation. CBS becomes fully operational in 2027 and IBS is phased in through 2033, but the new NF-e fields for IBS, CBS and the Selective Tax are already mandatory in 2026 under technical note 2025.002.

How far back can Brazilian tax credits be recovered?

Five years. For ICMS, the right to the credit expires five years from the issue date of the tax document (Complementary Law 87/96, art. 23, sole paragraph); for refund of overpaid tax, the period is the one in art. 168, I, of the Brazilian Tax Code.

How fast must a company react to a federal tax assessment?

Twenty business days. Supplementary Law 227/2026 amended Decree 70.235/1972 and replaced the former 30 calendar days, for both the administrative defense and the voluntary appeal to CARF.

Is the first conversation billed?

No. It is a 30-minute diagnostic with a senior consultant, free and with no commitment. The fee model is proposed afterwards, matched to the scope.