Brazil



World TP Reviews

Transfer pricing
Abe Rocha Neto Taparelli Garcez e Giovanini Advogados

The Abe Giovanini Advogados tax team consists of experienced litigators and advisors. It supports clients with tax assessments and matters related to liabilities and tax recovery, also guides its clients towards efficient tax performance in civil and commercial sales agreements, loans and leasing transactions. Key partners include Gustavo Barroso Taparelli and Juliana Cardoso. 

Details of the firm’s work and clients remains confidential.  

New tax partner Juliana Cardoso joined the team in 2020 and strengthened the advisory group. She focuses on transactional tax and general corporate tax. 

Barbosa Müssnich Aragão

The tax team at BMA has 13 partners and 30 lawyers who are active in the practice areas of tax controversy, general corporate tax and transactional tax, especially in M&A and cross-border transactions. The firm has offices in São Paulo, Rio de Janeiro and Brasília, but the tax team only operates in the São Paulo and Rio de Janeiro offices. Partner Luis Henrique Costa covers the transfer pricing practice.

Details of the firm’s work and clients remains confidential.

The team promoted Leticia Pelisson, who is specialising in tax litigation, as a partner during the research period.

Bueno & Castro Tax Lawyers

Launched in 2019, Bueno & Castro is a boutique law firm specialising in tax law. It is known for international tax matters. It provides planning and litigation to the commerce, digital and service economy sectors, as well as financial.

Details of the firm’s work and clients remains confidential.

CMARTINS Advogados

CMARTINS tax team specialises in tax plannings, advices and litigation. It is experienced in dealing mainly with clients from industry sectors such as telecom, IT, textile, foods and beverages, aviation, pharma, healthcare, consumer goods, energy and infrastructure, automotive and financial. 

Details of the firm’s work and clients remains confidential.

The team grew by adding two new partners, Mariana Cardoso Martins and Rodrigo de Assis Rodrigues, in 2020.

Deloitte

The tax team at Deloitte in Brazil, a highly reputable firm, is made up of more than 1,600 professionals. Carlos Ayub heads the transfer pricing team within the tax department. It works with multinational clients across multiple sectors such as oil and gas, mining, consumer goods, automobile, technology, financial services, and telecommunications.

During the research period the TP practice completed a customs assessment for an American healthcare subsidiary in the Brazilian market relating to intercompany imports. A successfully defence elevated the client of a substantive tax assessment. It also completed analysis on the cost-plus method application on import transactions.

Demarest Advogados

The transfer pricing team at Demarest Advogados falls under the tax department, which consists of 45 lawyers led by 10 partners and five of counsel. It specialises in working with clients in the automobile, pharmaceutical, life sciences and food and beverages sectors, to name a few.

The team are representing Visteon Amazonas S in an ongoing contentious case pertaining to IRPJ, CSLL, PIS and COFINS Assessment Notices awaiting a second level verdict. All additional material is confidential

Dias Carneiro Advogados

Dias Carneiro Advogados was founded in 2002 and since then has become a business-driven, hands-on practice. It is active among many sectors including pulp and paper, forestation, pharmaceutical, technology, telecommunications, and real estate.

All transfer pricing activity remains strictly confidential.

Felsberg Advogados

The tax department at Felsberg Advogados is led by a three-person team of Anna Flávia Izelli, head of tax litigation, Ivan Campos, head of tax in the Rio de Janeiro office and Rafael Malheiro, head of tax consulting and corporate tax in the São Paulo office. The team specialises in tax controversy, general corporate tax, and transactional tax, with an emphasis on M&A and cross-border transactions. It works with clients in the automobile, financial services, energy, retail, and pharmaceutical sectors.

All transfer pricing activity and associated clients remain confidential.

Fleury Coimbra Rhomberg Advogados

Eduardo Fleury heads the tax department at Fleury Coimbra Rhomberg Advogados. The team is active in tax consulting, tax controversy and transactional tax, specifically in cross-border transactions. Its strengths lie in the industrial and manufacturing, IT, oil and gas, clean energy, and healthcare sectors. It works with multinational firms and maintains strong relationships with international clients. 

The team represented Solinftec in complex cross-border issues to establish a tax structure for the international transactions of the company, pertaining to income of their foreign subsidiaries. This involved Double Taxation dimensions in cross-border context. All further material is confidential. 

Gaia Silva Gaede Advogados

The team at Gaia Silva Gaede Advogados has been providing a full range of transfer pricing services since 1996. It is spread out over five offices throughout Brazil, in Curitiba, Brasília, São Paulo, Rio de Janeiro and Belo Horizonte. Most of the clients the team works with are multinational companies. Partners Mauro da Cruz Jacob and Georgios Theodoros Anastassiadis are key TP contacts.

The team provided calculation adjustments derived from retrocessions agreements between Munich Re Brazil and its related parties abroad, according to the arm’s length methods. All further work remains confidential.

Lacaz Martins Pereira Neto Gurevich & Schoueri Advogados

A highly respected law firm, the tax department at Lacaz Martins Pereira Neto Gurevich & Schoueri Advogados provides consulting on international and domestic transactions, real estate, tax litigation, judicial litigation, and wealth management. Their tax department is composed of 23 partners and 9 qualified lawyers. Partners Luís Eduardo Schoueri and Daniel Vitor Bellan are TP practitioners.

Transfer pricing activity over the research cycle remains strictly confidential.

Lefosse Advogados

The tax team at Lefosse Advogados provides full tax services and is active among many sectors, including agribusiness, tobacco, pharmaceutical, IT, education and food and beverages. Its clients range from large multinationals to local Brazilian corporations and private equity firms. The team is made up of more than 40 professionals.  

 

All client’s names and details of their work remain confidential.

Machado Associados Advogados & Consultores

Founded in 1990, Machado Associados Advogados & Consultores tax team is made up of 50 professionals, 22 of whom are partners. It works across three offices throughout Brazil, in São Paulo, Rio de Janeiro and Brasília. The international taxation and transfer pricing team is one of four working teams within the tax department. It specialises in the automobile and manufacturing sectors. Partner Stephanie Makin is the main transfer pricing contact.

In the last 12 months, the group worked on numerous transfer pricing cases. All matters and clients remain confidential.

Machado Meyer Sendacz & Opice Advogados

The tax team at Machado Meyer Sendacz & Opice Advogados is led by 16 partners. It prides itself on providing a boutique tax firm experience within a full-service law firm. Operating out of offices in Brasília, São Paulo and Rio de Janeiro, the team works with clients over many sectors such as construction, telecommunications, energy, financial services and oil and gas. Partners Raquel Novais, Fernando Tonanni, Fernando Colucci and Bruna Marrara Martinez are the central TP practitioners.

All transfer pricing material remains strictly confidential.

Mallard Medeiros Advogados

The practice is a full-service law firm with multifaceted expertise across corporate restructuring, M&A transactions, customs planning and real estate portfolios. Industry expertise covers mining, life sciences, technology, and healthcare.  Head of tax is partner Maria Victória Leôncio de Melo Pinheiro de Campos.

Mannrich e Vasconcelos Advogados

Founded in 2004, Mannrich e Vasconcelos Advogados specialises in working with the healthcare, chemical, agribusiness and mining sectors. Its tax team is active in tax controversy and general corporate tax. Partners Breno Ferreira Martins Vasconcelos and Thais Romero Veiga Shingai are key individuals at the firm. 

 

All transfer pricing material remains strictly confidential.

Marchant TP

Founded in 2015, Marchant TP is a Brazilian law firm known for its pioneering specialisation in transfer pricing. Its work covers several industries including aviation, commodities, pharmaceutical and electronic manufacturing. Partner Diego Marchant is the senior specialist with a coveted academic reputation in the Brazilian market.

All details and names of clients remain confidential. 

Martinelli Advogados

Martinelli Advogados is well known and brings a large team to tackle a wide variety of transfer pricing issues. The team regularly advises companies with large international footprints and uses a unique approach to tax review works, identifying legal alternatives for reducing the client’s tax burden. Partners Bruno Condurú Davis and Roberto Melo Franco Corrêa are the main TP practitioners.

All details and client names remain confidential.

Pinheiro Neto Advogados

Pinheiro Neto Advogados has one of the leading transfer pricing practices within the Brazilian market, representing national and multinational companies at administrative and judicial litigations. The team also provides general legal advisory on transfer-pricing matters, including planning, audit, tax treaties, APA’s and MAP’s. Senior associate Felipe Cerrutti Balsimelli is a key individual within the transfer pricing practice.

Over the research period, the TP practice provided litigation for Schaeffler Brasil in a transfer pricing dispute with the Brazilian tax authorities regarding federal taxation on imports carried out between Schaeffler’s Brazilian subsidiary and related parties in Germany. It also litigated in a transfer pricing dispute for Japanese automobile manufacturer Honda.