Possible solutions
The routes we work with at each stage of a tax matter, in plain language.
01Prevention and planning
- Preventive advice to reduce risks
Legal review of the transactions, contracts and tax positions of a business or estate, to identify risks and address them before they turn into assessments or disputes.
- Legal opinion
A reasoned technical opinion on a specific tax question. It guides the decision and documents the rationale, supporting the client's position.
- Formal ruling request
A request for the tax authorities to state officially how the law applies to a specific fact. While pending, it generally protects the taxpayer from penalties on the matter.
- Tax planning
Analysis of lawful alternatives to organize operations and structures more tax-efficiently, with legal certainty and proper documentation.
- Wealth structuring
Organizing personal and family wealth tax-efficiently, including the analysis of holding companies and how assets are held.
- Succession planning
Preparing the transfer of wealth between generations, with gifts and protective clauses and attention to the state inheritance and gift tax (ITCMD), to reduce future costs and disputes.
- Tax credit recovery
Identifying, from a legal standpoint, overpaid or unduly paid taxes and unused credits, and recovering them through administrative or judicial channels.
- Tax reform
An advisory committee for implementing the reform: assessing the impact on prices and contracts, reviewing contracts, using credits and monitoring the regulations.
02Audit and assessment
- Tax audit support
Guidance during the tax audit, in answering notices and delivering documents, so that communication failures do not lead to an assessment.
- Administrative defense and appeals
A challenge to the tax assessment and appeals to the administrative bodies, such as CARF at the federal level and TIT in São Paulo. While under discussion, collection of the debt is suspended.
- Installment plan
Splitting the debt into installments under ordinary or special programs. It suspends collection and allows the taxpayer to obtain a tax clearance certificate.
03Collection and litigation
- Tax settlement
An agreement with the tax authorities to settle debts, possibly with reduced penalties and interest and longer terms, depending on each program or proposal.
- Procedural agreement
An agreement with the government's attorneys to adjust how registered tax debts are collected, such as deadlines, guarantees and payment terms.
- Strategic tax litigation
Handling tax disputes in court with a strategy built for each case: preventing a demand before it is made, or defending assets against collection. Writs of mandamus, declaratory and annulment actions and defenses in tax enforcement proceedings, among others, are the tools, chosen according to the goal, the timing and the risk.