Castro Barros Sobral Gomes Advogados

Brazil

Address:
Av. Rio Branco, 110, 14th Floor
Rio de Janeiro, 20040-001
Brazil

+55 21 21321800


Key contacts:

Partner: André Gomes de Oliveira
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Quick facts:

Number of advisers: 20
Network memberships: Brazilian Bar Association, Brazilian Academy of Tax Law (ABDT), International Fiscal Association (IFA), International Bar Association (IBA), British Chamber of Commerce and Industry, International Association of Young Lawyers (AIJA)
Languages: Portuguese, English, Spanish and French


CBSG's tax practice is very active not only in domestic and international consultancy and planning for clients, but also in administrative and judicial litigation, including participation in relevant cases heard by the higher administrative and judicial courts.

The tax consulting and tax planning practice consists of assistance to domestic and foreign companies in determining the taxes and other levies that directly and indirectly influence their activities, considering the specificities of the fiscal regimes applicable to each segment of the economy. It also provides assistance to Brazilian and foreign individuals in all matters related to income tax, including reviewing capital gains and income tax returns.

Because of its tradition of working with multinationals, the tax department of CBSG has extensive experience with international taxation, cross-border transactions, multilateral tax treaties and structuring of investments and operations, the tax aspects of importing and exporting products and services, including preferential tariff treatment under international agreements, customs valuation, special customs regimes and systems, tax classification and transfer pricing.

The department is also very active in strategic tax litigation in the administrative and judicial spheres, acting in all instances and spheres (municipal, state and federal), and currently handles approximately 3,000 judicial and administrative tax cases, in all Brazilian states.

Our office in Brasília enables CBSG to have presence in the highest judicial and administrative courts and follow the leading cases related to the main tax issues currently under discussion.

Tax Advisory

André Gomes de Oliveira, Patrícia Varela Gomes and Leandro Bertolo Canarim

Senior Partner and Senior Associates

andre.oliveira@cbsg.com.br, patricia.varela@cbsg.com.brleandro.canarim@cbsg.com.br

Assistance provided to Level Up! Interactive S.A on the taxation of its activities in Brazil, considering the discussion regarding the nature and applicability of the ICMS or ISS on the payments made to foreign developers under software licensing agreements. This is a very complex and controversial matter in Brazil.

 

Tax Advisory

André Gomes de Oliveira and Gabriel Manica Mendes de Sena

Senior Partner and Partner

andre.oliveira@cbsg.com.brgabriel.manica@cbsg.com.br

Assistance provided to Neutrona Networks International LLC in setting up a Brazilian subsidiary to provide telecommunication services in the country and advice on the best business model, taxation of importation of equipment, tax credits and telecommunication services. This engagement reinforces CBSG’s position as a national leader and first-choice provider in the telecommunications business.

 

Tax Litigation

André Gomes de Oliveira, Daniela Duque Estrada, Gabriel Manica and Lorena Cavalcante Lopes  

Senior Partner, Partner, Partner and Senior Associate

andre.oliveira@cbsg.com.br, daniela.duqueestrada@cbsg.com.br, Gabriel.manica@cbsg.com.brLorena.lopes@cbsg.com.br

Assistance provided to Casa & Video Rio de Janeiro S.A. in a strategic administrative defense in a complex tax assessment issued by the Rio de Janeiro State Revenue Secretariat (SEFAZ/RJ) aiming to collect the ICMS on the inventory of the company’s distribution center. CBSG was able to prove in detail the many mistakes made by the tax authorities in determining the chargeable amount, which led the State Tax Appeal Council to unanimously order the dismissal of the assessment and to cancel de debts definitively in August 2017.

 

Tax Litigation

André Gomes de Oliveira, Daniela Duque Estrada, and Thiago Francisco Ayres da Motta

Senior Partner, Partner and Senior Associate

andre.oliveira@cbsg.com.br, daniela.duqueestrada@cbsg.com.brthiago.motta@cbsg.com.br

Assistance provided to IRB challenging a tax assessment involving deducting from the base for calculating the PIS and COFINS losses caused by exchange rate variations. The Superior Tax Appeals Chamber upheld the decision canceling most of the debts charged, concluding that exchange rate variations should not be included in PIS and COFINS calculation basis.