PRACTICES

 

We offer unique consulting services that involve the transfer of our know-how, allowing our clients to further understand the fiscal consequences of their transactions and also obtain:

 

  • Training of employees responsible for each relevant area.

 

  • Significant improvement on their ability to identify inconsistencies between actual situations and legal provisions, finding alternative solutions to minimize tax exposure.

 

  • Viability to tax and financial planning.

 

  • Self-organization and independence.

 

 

Click on one of the links below for more details:

 

Transfer Pricing


  • Implantation and management of transfer pricing control, oriented to producing the information necessary to comply with the tax administration’s requirements.

  • Revision of the transfer pricing methodology employed by our clients.

  • Transactional analysis – analysis based on documents, cost spreadsheets, inventory control, productive processes and commercialization to identify identical and similar products. We also analyze the possibility of changing the employed Transfer Pricing control method to seek a smaller tax exposure, checking for inconsistencies between actual situations and legal provisions and finally suggesting the most appropriate corrective measures.

  • Filing and monitoring of profit margin alteration requests.

  • Development and monitoring, from a tax perspective, of export plans regarding the conquest of foreign markets.

  • Undertaking of studies and researches to prove the appropriateness of our clients’ prices, based on supplementary evidence.

  • Filing of consultation proceedings before the Federal Revenue of Brazil regarding the interpretation of tax law.

  • Elaboration of studies, research and technical opinions.

  • Monitoring of tax inspections.

  • Challenge of tax assessments before the Federal Revenue of Brazil.

  • Training, lectures and seminars, inclusively in-company.

    •

    Return to the top



    Thin Capitalization


  • Calculation of the debt/equity ratios for each company.

  • Preparation of projections to determine the best alternative to fund the Brazilian company from a tax perspective (dividends, interest on net equity, interest from loans).

    •

    Return to the top



    Worldwide Income Taxation


  • Analysis of the clients’ organizational chart, seeking to identify tax exposures while proposing measures to improve the company’s international strategy.

  • Elaboration of studies, research and technical opinions.

  • Filing of consultation proceedings before the Federal Revenue of Brazil regarding the interpretation of tax law.

  • Monitoring of tax inspections.

  • Challenge of tax assessments before the Federal Revenue of Brazil.

  • Analysis of tax benefits deriving from international tax treaties entered into by Brazil.

    •

    Return to the top



    Non-resident Income Taxation


  • Filing of consultation proceedings before the Federal Revenue of Brazil regarding the interpretation of tax law.

  • Elaboration of studies, research and technical opinions.

  • Monitoring of tax inspections.

  • Challenge of tax assessments before the Federal Revenue of Brazil.

  • Analysis of tax benefits deriving from international tax treaties entered into by Brazil.

    •

    Return to the top



    Litigation


    Besides consulting, we also protect our clients’ interests directly before the Federal Revenue of Brazil. Our services comprise all aspects of administrative litigation, from challenging tax assessments to performing oral arguments before the Taxpayer’s Council (Conselho de Contribuintes) and the Superior Chamber of Tax Appeals (Câmara Superior de Recursos Fiscais).

    Our litigation services include:


  • Challenging of tax assessments.

  • Appeals to the Taxpayer’s Council.

  • Appeals the Superior Chamber of Tax Appeals.

    •

    Return to the top