Tax

The constant change in the Brazilian law in tax matters, the complexity of the Brazilian tax system, and the significant quantity of taxes and ancillary obligations make the good advisory in tax matters an essential element for the daily transactions of any company or even individuals.

Law firm  MAZZUCCO & MELLO ADVOGADOS provides broad advisory in the area of Tax, Customs and Social Security Law with experienced professionals and personalized service, acting in litigation and advisory services related to these areas.

Advisory services

Support in a broad range of tax matters involving direct and indirect taxes, tax advisory in corporate restructuring (M&A) transactions and purchase of investments, joint ventures, sale of assets and goodwill, due diligences, tax planning, including international, taxation of returns earned by non-resident individuals and legal entities, advisory in the implementation of tax compliance policies, and management and administration of liabilities with adoption of strategies for tax efficiency and tax savings.

MAZZUCCO & MELLO ADVOGADOS also provides advisory services in the social security area and in issues involving taxation of foreign trade transactions and obtainment of special regimes and tax incentives.

Litigation

MAZZUCCO & MELLO ADVOGADOS operates throughout the Brazilian territory in the defense of the interests of its clients in all jurisdictions of the Judiciary, in the adoption of legal measures for questioning the enforcement of taxes and for recovery of credits, in addition to handling administrative litigation at federal, state and municipal levels, presenting defense to tax assessment notices and acting administratively in proceedings for refund and offset of taxes.

MAZZUCCO & MELLO ADVOGADOS also provides support to its clients in the follow-up of tax inspections and adoption of measures for actual compliance therewith.

Application for tax incentives
  • Assistance to Pay-tv company and Pay-tv association and negotiation with State Tax authorities of the VAT levied over internet and pay-tv companies, claiming the right of not paying VAT tax over Pay-tv industry; negotiation with State Tax authorities.
Legal advice - special regime for repatriation of undeclared funds and assets 
  • Assistance to several individuals and legal entities with the application to the Special Regime for Repatriation of Undeclared Funds and Assets (real estate properties, financial investments, cash, heritage, intangible assets), drafting the necessary statements and documents to enable the inflow of funds. 
Support in tax inspections
  • Assistance to several Brazilian and multinational companies with the attendance of tax inspections related to taxes and social contributions by presenting all documents and necessary information for restraining tax assessment notices and enforcement proceedings. 
Tax consultancy - admission to special installment payment programs
  • Assistance to several companies (automobile parts, infrastructure, energy, retail, industry and services) in the application for special installment tax regimes (in the Federal, State and Municipal level), with presentation of numerical simulations considering the different options granted by each regime and filing and submission of the necessary application forms. 
Legal advice in the comprehension of the importation proceedings adopted in brazil for filing a judicial claim in the UK
  • Drafting of legal opinions and reports for the purpose of filing a statement of claim in UK, with a brief explanation of the tax burden levied on the importation of luxury boats and yachts and other peculiarities of the importation and customs clearance of such goods. 
Monthly tax consultancy - housekeeping 
  • Monthly tax consultancy to several airline companies that operate in Brazil in relation to the tax returns to be filed in Brazil; reviewing of tax returns (SPED, ECF, EFD, DIRF, DCTF) and regular ascertainment of taxes, penalties and interest, when applicable. 
Tax consultancy and advisory to expatriates 
  • Assistance to expatriates of multinational companies with matters related to the declarations on income and assets earned in Brazil and abroad. 
Tax consultancy - tax incentives - local assembly of products
  • Advising the subsidiary of an American manufacturer of household appliances and electronic devices in the identification of tax incentives (at the Federal, State and Municipal level) and financial advantages for establishing an assembly line of products in Brazil.  
Tax litigation /negotiation of tax debts / management of tax liabilities 
  • Filing of judicial claims challenging the incidence of the VAT on telecom services; negotiating settlement with São Paulo State Tax Authorities about VAT over the Pay-tv industry.
Litigation - tax optimization
  • Advising international airline companies in filing judicial claims aiming the recognition of reciprocal treatment for income tax and withholding income tax exemption levied on the revenues earned with the sales of tickets in Brazil and on the amounts remitted abroad. 
Litigation - tax reduction/optimization
  • Assistance to a networking management company in filing a judicial claim to restrain the collection of the Tax on Services (ISS) on royalties paid under franchising agreements entered into in Brazil and with master franchisors domiciled abroad. 
Administrative tax litigation
  • Assistance to a telecom company in drafting and filing defense of a tax assessment notice related to a wrong amortization of goodwill in a corporate restructuring transaction, which the updated amount involved is higher than BRL 50,000.000.00
  • Assistance to one of the major Brazilian manufacturers of ceramics and sanitary components in drafting and filing defense of a tax assessment notice with regard to the offset of credits of PIS/COFINS and IPI related to the acquisition of inputs and raw material, whose updated amounts were R$ 150,000.000.00. 
Tax administrative and judicial litigation 
  • Managing portfolio of administrative and judicial tax claims involving one of the major Brazilian cellulose producers, composed by 400 claims, whose amounts involved were greater than BRL 8,000.000.00.
  • Managing portfolio of administrative and judicial tax claims involving the Brazilian subsidiary of an American IT company, composed by 250 claims, whose amounts involved were greater than BRL 8,000.000.00.
  • Managing portfolio of judicial tax claims involving the Brazilian subsidiary of a south Korean company which sells electronic devices, cell phones, petrochemical products, and machinery, composed by 100 tax enforcement proceedings, whose amounts involved were greater than BRL 60,000.000.00.
  • Managing portfolio of administrative and judicial tax claims involving the Brazilian branch of an American car rental company, composed by 130 claims, whose amounts involved were greater than BRL 7,000.000.00.
  • Managing portfolio of administrative and judicial tax claims involving a Brazilian network of hospitals, composed by 250 claims, whose amounts involved were greater than BRL 36,000.000.00.
Tax litigation /negotiation of tax debts / management of tax liabilities 
  • Managing portfolio of administrative and judicial tax claims involving a Brazilian outsourcing company, whose debts were greater than BRL 100,000.000,00; developing an action plan for managing such tax liabilities and for negotiating potential reductions with the Federal, State and Municipal Attorneys Offices. 
Administrative application for tax recovery
  • Assistance to several companies in requesting recovery of unduly collected VAT (ICMS) amounts with The State Treasury´s Offices; assistance in filing the necessary statements and monitoring related inspections. 
Negotiation of tax debts / management of tax liabilities 
  • Assistance to a manufacturer of plastic packaging in developing an action plan for managing such tax liabilities and for negotiating potential reductions with the Federal, State and Municipal Attorneys Offices. 
Application for special regimes for customs 
  • Assistance to a swiss offshore drilling company in the application for special regimes for importing oil drilling equipment, enabling a tax saving of approximately BRL 5,000.000.00. 
  • Assistance to a Norwegian company of oil and gas prospecting in the application for importing oil drilling equipment, enabling a tax saving of approximately BRL 6,000.000.00.  
  • Assistance to an Argentinian airline company in the application of a special customs regime before the Brazilian IRS for warehousing of parts and equipment for aircraft maintenance with suspension of taxes generally due upon such equipment´s customs clearance. 
  • Assistance to a Turkish airline company in the application of a special customs regime before the Brazilian IRS for warehousing of parts and equipment for aircraft maintenance with suspension of taxes generally due upon such equipment´s customs clearance. 
Tax recovery 
  • Assistance to an infrastructure company in filing judicial claims and administrative proceedings aiming the recovery of federal, state, and municipal taxes levied on supply chain, importation of goods, acquisition of raw material and payroll. 
  • Assistance to an importer and reseller of steel cables in filing judicial claims and administrative proceedings aiming the recovery of federal, state, and municipal taxes levied on supply chain, importation of goods, acquisition of raw material and payroll. 
  • Assistance to an American multinational company manufacturer of automobile parts in filing judicial claims and administrative proceedings aiming the recovery of federal, state, and municipal taxes levied on supply chain, importation of goods, acquisition of raw material and payroll. 
  • Assistance to an IT swiss company in filing judicial claims and administrative proceedings aiming the recovery of federal, state, and municipal taxes levied on supply chain, importation of goods, acquisition of raw material and payroll. 
  • Assistance to one of the major Brazilian cellulose producers in filing judicial claims and administrative proceedings aiming the recovery of federal, state, and municipal taxes levied on supply chain, importation of goods, acquisition of raw material and payroll. 
  • Assistance to an infrastructure Brazilian company in filing judicial claims and administrative proceedings aiming the recovery of federal, state, and municipal taxes levied on supply chain, importation of goods, acquisition of raw material and payroll. 
Tax review and consultancy 
  • Assistance to a major Brazilian developer of energetic efficiency projects in reviewing VAT State Tax Credits (ICMS) offset by the company in several calendar years, with identification of the amounts unduly offset, of potential contingencies and of the chances of annulment/reduction in the administrative and judicial level.