All publications
Books and articles by the partners, most recent first.
Books
Articles
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Sep 24, 2026
Administrative litigation Uniformisation proceedings in the new administrative tax litigation
Complementary Law 227/2026 created uniformisation proceedings in the new administrative litigation for IBS and CBS.
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Sep 10, 2026
Higher courts The role of the Superior Court of Justice in tax law
In tax matters, the Supreme Court (STF) and the Superior Court of Justice (STJ) should not be seen as a hierarchy, but as courts with distinct jurisdictions.
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Aug 13, 2026
Tax interpretation Interpretations that render tax rules ineffective
When describing taxable events, the legislator makes value choices; interpreting tax law also means dealing with values.
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Jul 30, 2026
Tax reform IBS, CBS and the export of services
The IBS and CBS export immunity for services follows from the destination principle and neutrality.
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Jul 16, 2026
Tax reform On the concept of services in Brazil’s consumption tax reform
Under the reform, a “service” should be defined residually: whatever is not a transaction with goods, without inheriting the old ISS concepts.
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Jul 2, 2026
Corporate income tax Taxation of ICMS incentives: following binding precedent and the law is not a “thesis”
The regime of article 30 of Law 12,973/14, before its repeal by Law 14,789/23, also covers ICMS exemptions and tax-base reductions, not only presumed credits.
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Jun 18, 2026
Intellectual services Article 129 of Law 11,196/05 as a legal fiction
Article 129 of Law 11,196/05 creates a legal fiction: intellectual services provided through a company are treated, for tax and social security purposes, as the company’s.
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Jun 4, 2026
Tax reform There is no personal use or consumption in a taxpayer’s business activity
The ban on credits for “personal use or consumption” is an exception to the broad IBS and CBS credit right and must be read narrowly.
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May 21, 2026
Tax reform On IBS and CBS as consumption taxes
Treating IBS and CBS as “consumption taxes” is not only an economic reading: it explains legal features of their regime.
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May 7, 2026
Tax reform On the IBS regulation and refunds under the tax reform
Article 486, III, of the IBS Regulation allows refunds to be denied while an IBS assessment is still being challenged administratively.
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Apr 23, 2026
Tax reform Towards a new theory of the tax obligation for IBS and CBS
The National Tax Code model, in which the taxable event creates the obligation and the assessment constitutes the credit, needs to be broadened for IBS and CBS.
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