Tax Law

Advisory

FI&F provides advice on tax law issues in general, including all Federal, State and Municipal taxes levied on daily activities or specific transactions of companies and individuals, including analysis of tax incentives or special tax regimes.

FI&F has experience in assessing the tax impacts of structuring and restructuring business operations, mergers and acquisitions, joint ventures and other corporate associations, asset deals, and other corporate reorganizations, focusing on improving tax efficiency and preventing potential tax liabilities.

FI&F assists clients in cross border transactions, providing the best tax structure to do business in other countries, and foreign companies that invest in Brazil (outbound and inbound), including the application and interpretation of Tax Treaties and the Brazilian transfer pricing rules.

FI&F also has expertise regarding individual taxation, including filling of annual reports, expatriation or change of tax residence to or out of Brazil and estate planning.

Litigation

FI&F represents the interests at all levels of the Judiciary Branch, including superior courts. FI&F assists its clients in establishing the best strategy to avoid the payment of undue taxes or to recover amounts unduly paid by defining best type of legal action to be adopted.

At the administrative level, FI&F represents its clients before Federal, State and Municipal tax administrative courts and assists them by drafting defenses against tax assessments, as well as proceedings related to requests to refund or offset of taxes.

Due Diligence

From a tax standpoint, FI&F assists its clients on the ascertainment of contingencies, by verifying tax routines and compliance with the collection of taxes and compliance with ancillary obligations, including the assessment of judicial and/or administrative proceedings involving companies and individuals.

Customs Law

FI&F provides assistance for compliance with customs and tax legislation rules, including review of procedures, calculation and collection of customs taxes and duties.

FI&F also assists Brazilian clients structuring their international trade business and/or helping foreign companies that want to invest in Brazil by analyzing and providing alternatives to reduce or suspend the payment of customs taxes through the adoption of special customs regimes such as drawback, temporary admissions, and bonded warehouses; defining the correct tariff classification of goods, or requesting the application of ex tarifários (reduction of import tax for a specific good).

FI&F’s expertise on tax litigation includes customs, so FI&F also represents clients at the administrative and/or judicial levels up to highest courts.

Corporate Law

FI&F assists clients in drafting, analyzing and/or negotiating commercial contracts in general.

FI&F advices its clients on matters relating to investors’/shareholders’ rights, corporate governance, corporate disputes and foreign investments in Brazil, including the analysis of the Brazilian Central Bank rules and requirements.

FI&F assists clients on business organization and on the preparation of corporate documents  such as amendments to articles of association and by-laws, voting and shareholders’ agreements, minutes of shareholders´ meetings and officers’ appointments.

FI&F also provides support to corporate reorganizations, including mergers and acquisitions (M&A), spin-offs, joint ventures, consortium agreements, silent partnerships and other forms of business associations.

Along with the tax practice, FI&F assists in estate planning, structuring family and management holding companies, drafting corporate governance policies, preparing wills, instruments of donation and usufruct, and analyzing the legal consequences in Brazil of international estate planning structures.