Advice on negotiating tax incentives

• Administrative consultancy for a Pay-TV company and for the Brazilian Subscription Television Association on negotiations with Confaz with the aim of structuring the incidence of ICMS on subscription television operations, negotiating a reduction in the calculation basis, and other institutional aspects of the tax.

RERCT Consulting

• Advice to various individuals and legal entities during the repatriation of resources from abroad (real estate, financial investments, money, inheritance, intangible assets), offering support in preparing the necessary documents and with banks to close the resource entry operations.

Inspection service and support

• Advice to companies from various segments, national and multinational, in responding to federal, state and municipal inspections related to taxes and social security contributions, with the presentation of clarification documents and adoption of necessary measures to prevent possible fines.

Consulting – joining debt installment plans

• Advice to various companies (automotive, infrastructure, energy, retail, industry and services sectors) on procedures for joining debt installment plans at the Federal (REFIS, PERT), State (PEP – ICMS and similar) and Municipal levels, with presentation of the respective simulations involving the different types of joining and formalization of requests with the administrative authorities.

Consulting – application of Brazilian legislation for the purpose of filing legal action abroad

• Preparation of opinions and papers to assist in filing collection and compensation actions in the United Kingdom, with a description of the tax burden on the import of products, such as luxury speedboats and yachts, and peculiarities related to the import and nationalization stages of said products.

Monthly consultancy – housekeeping

• Monthly consultancy to several foreign airlines that operate regular flights in the country regarding compliance with ancillary obligations in Brazil; review of declarations (SPED, ECF, EFD, DIRF, DCTF), tax review and advice on the calculation and collection of taxes.

Tax consultancy – services for expatriates

• Advice to expatriates of foreign companies operating in Brazil regarding the declaration of income earned in Brazil and abroad.

Tax consultancy – tax benefits for product assembly lines

• Consulting for the Brazilian subsidiary of an American company that manufactures home appliances and electronics in identifying favorable regions for the installation of an assembly line in Brazil, considering financial incentives and federal, state and municipal tax benefits.

Litigation – ICMS telecommunications and debt negotiation

• Filing of lawsuits challenging the incidence of ICMS on telecommunications services and assistance in an agreement with the Attorney General's Office of the State of São Paulo to withdraw lawsuits and pay the amounts.

Litigation – tax optimization

• Advising foreign airlines on filing a lawsuit seeking recognition of reciprocal treatment for the purposes of exemption from IRPJ and IRRF on proceeds from airline ticket sales in Brazil and the remittance of such revenues abroad.
• Advising the national organization of business references on filing a legal action to eliminate ISS on royalties paid in franchise agreements signed in Brazil and with the master franchisor abroad.

Administrative litigation

• Advising a telecommunications company on challenging a notice of violation related to the undue amortization of goodwill in a corporate restructuring transaction worth more than R$$50,000,000.00, including fines and interest.
• Advising a leading Brazilian company in the manufacture of sanitary ware and metals in challenging a notice of violation related to the use of PIS/COFINS and IPI credits on inputs, the value of which corresponded to R$150,000,000.00, including fines and interest.

Portfolio management – administrative and judicial litigation

• Management of a portfolio of administrative and judicial proceedings for a Brazilian company that is a world leader in the production of cellulose, with an average of 400 active and passive proceedings, with a value involved equivalent to R$$ 8,000,000.00.
• Management of a portfolio of administrative and judicial processes for the Brazilian subsidiary of an American technology company, with an average of 250 active and passive processes, with a value involved equivalent to R$$ 8,000,000.00.
• Management of a portfolio of legal proceedings for a Brazilian subsidiary of a South Korean conglomerate operating in the electronics, cell phones and petrochemical products, energy, machinery, metals, finance and services sectors, with an average of 100 tax executions worth R$60,000,000.00.
• Management of a portfolio of administrative and judicial processes for an American vehicle rental company, with an average of 130 active and passive processes worth R$7,000,000.00.
• Management of a portfolio of administrative and judicial processes for the ABC hospital network, with an average of 250 active and passive processes worth R$$ 36,000,000.00.

Portfolio management – administrative and judicial litigation/extrajudicial negotiation of debts/disposal of tax liabilities

• Advice to an accounting and payroll outsourcing company in the management of a portfolio of processes with tax liabilities valued at R$100,000,000.00. Development of a strategy for the disposal of said liabilities and negotiation of debts with the Attorney General's Offices through extrajudicial means or through the execution of a procedural legal transaction.

Administrative qualification of credits

• Advice to several companies in the qualification of their own ICMS and ST credits with the Finance Departments of several States, through the assembly of the respective magnetic files and monitoring of related inspections.

Extrajudicial negotiation of debts/disposal of tax liabilities

• Advising a company that manufactures tarpaulins and plastic packaging in developing a strategy to cover tax liabilities worth approximately R$500,000,000.00 and negotiating said liabilities with the Public Prosecutors' Offices via extrajudicial means or through the execution of a procedural legal transaction.

Obtaining special regimes – customs

• Advising a Swiss offshore drilling company on obtaining special import regimes for oil well drilling equipment, enabling tax savings in the order of R$$ 5,000,000.00.
• Advising a Norwegian state-owned natural gas and oil extraction company on obtaining special import regimes for oil drilling equipment, enabling tax savings in the order of R$$ 6,000,000.00.
• Advising an Argentine airline on obtaining a customs regime for secured deposit with the Federal Revenue Service for the purpose of storing, with suspension of taxes, imported materials without foreign exchange coverage intended for aircraft maintenance and repair.
• Advising the Turkish airline on obtaining a customs regime for secured deposit with the Federal Revenue Service for the purpose of storing, with suspension of taxes, imported materials without foreign exchange coverage intended for the maintenance and repair of aircraft.

Credit recovery

• Advising companies in the infrastructure sector on legal actions and administrative procedures aimed at recovering tax credits of various natures related to taxation on the production chain, import of goods, raw materials and inputs, and payroll.
• Advising a steel cable importing and resale company in legal actions and administrative procedures aimed at recovering tax credits of various natures related to taxation on the production chain, import of goods, raw materials and inputs and payroll.
• Advising an American multinational company in the automotive parts and components segment in legal actions and administrative procedures aimed at recovering tax credits of various natures related to taxation on the production chain, import of goods, raw materials and inputs, and payroll.
• Advising a Swiss multinational technology company on legal actions and administrative procedures aimed at recovering tax credits of various natures related to taxation on the production chain, import of goods, raw materials and inputs, and payroll.
• Advising a Brazilian company, a world leader in the production of cellulose, in legal actions and administrative procedures aimed at recovering tax credits of various natures related to taxation on the production chain, import of goods, raw materials and inputs, and payroll.
• Advising a Brazilian infrastructure company on legal actions and administrative procedures aimed at recovering tax credits of various natures related to taxation on the production chain, import of goods, raw materials and inputs, and payroll.

Tax review and consultancy

• Advising a leading Brazilian company in energy efficiency projects on the review of ICMS and ICMS ST credits appropriated by the company in previous calendar years, identifying credits taken unduly, potential contingencies and the chances of defending the cancellation of some amounts in the administrative and judicial spheres.