Tax

Barbieri Advogados acts in tax law across the three levels of Brazilian taxation — federal, state and municipal — through a practice that combines advisory and contentious work. The practice operates at a moment of structural transformation in the tax system: the Brazilian Tax Reform, in its phase of regulation and transition, redefines well-established premises in tax planning, recovery of tax credits, and tax litigation. The firm guides each client through this transition, with a rigorous technical reading of the changes and strategies calibrated to each client’s specific exposure.

The practice is structured around three main pillars. In advisory work, the firm acts on tax planning and fiscal structuring of corporate transactions, mergers, acquisitions and family holding companies; preventive advice on the interpretation of legislation and tax classification; and the drafting of opinions on specific transactions. In contentious work, the firm defends taxpayers in tax assessments and administrative proceedings before the Federal Administrative Tax Tribunal (CARF), the São Paulo State Tax Tribunal (TIT), state-level administrative tax tribunals (TAT), and similar bodies; in mandados de segurança (constitutional writs against acts of public authority), declaratory actions and ordinary actions against tax demands; and in tax enforcement proceedings and embargos (objections to enforcement). In tax credit recovery, the firm conducts retrospective tax reviews, identifying taxes paid in error, and pursues the administrative and judicial measures necessary for the refund or offset of amounts owed.

Business Crime is integrated into the practice where matters at the frontier of tax and criminal law arise.