Brazuna Ruschmann & Soriano Sociedade de Advogados


Rua Pequetita, 215, cj. 11
São Paulo - SP 04552-060

+50 11 3185 0600

Key contacts:

Partner: José Luis Ribeiro Brazuna
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Partner: Cristiano Frederico Ruschmann
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Partner: Ciro Soriano de Oliveira
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Quick facts:

Number of advisers: 15
Languages: Portuguese, English, Spanish and German

Tax boutique with pragmatic approach, creative and business-sensitive, combining technical capability with strategic view of the Brazilian tax legislation.

BRATAX covers both tax consultancy and litigation matters on behalf of multinational clients from several segments, specially IT, chemical and pharmaceutical industries, human and animal nutrition, renewable energy, infrastructure, cosmetics, laboratorial services, automobile and foreign trade.

BRATAX's transfer pricing expertise has been helping clients in complex litigation cases, as well as in planning new activities setting-up in Brazil.

Transfer Pricing Firm of the Year in 2015, according to Americas Tax Awards.

  • International tax planning
  • Business restructuring
  • Business model optimisation
  • Audit defence
  • TP risk management
  • Cost-sharing arrangements
  • Dispute resolution
  • Litigation
  • Controversy management


  • Agriculture
  • Automotive
  • Construction and materials
  • Consumer goods and services
  • Energy, Food and beverage
  • Gaming
  • Government and public policy
  • Healthcare
  • Industrials
  • Media
  • Mining
  • Pharma and life sciences
  • Real estate
  • Tech and telecoms
  • Utilities

Transfer-pricing judicial dispute

Ciro Cesar Soriano de Oliveira


Judicial disputes related to the application of illegal TP methods on pharmaceutical multinationals.  Leading cases on the illegality of Brazilian IRS ordinance n. 243.


Transfer-pricing tax assessment disputes

Ciro Cesar Soriano de Oliveira / José Luis Ribeiro Brazuna

Partners /

Administrative defences against notices of tax infraction accusing clients from pharmaceutial and technology industries of incorrect TP adjustment on their corporate tax calculation.  Different legal and factual issues have been discussed on these cases, according to each specific situation.


Transfer-pricing advisory in structuring fashion activity in Brazil

Cristiano Frederico Ruschmann


Advising to big European fashion company in studying tax wise alternatives for setting-up activities in Brazil, considering TP local legislation.


Transfer-pricing advisory on financed importations

José Luis Ribeiro Brazuna


Advising to European food company in complying with Brazilian TP legislation in relation to financed importations from related parties.


Transfer-pricing APA under DTT bilateral controversy proceeding

Cristiano Frederico Ruschmann


Support to client in negotiating with Brazilian tax authorities the indirect observation of an European APA, under the use of administrative DTT bilateral controversy proceeding.

Avenida das Américas, 700, bloco I, sala 332

Rio de Janeiro - RJ 22460-100


T: +55 21 2431 2303