Firm / Organisation

Schneider, Pugliese, Sztokfisz, Figueiredo e Carvalho Sociedade de Advogados

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This content is provided by Schneider, Pugliese, Sztokfisz, Figueiredo e Carvalho Sociedade de Advogados.

Managing Partners: Cassio Sztokfisz
Senior Partners: Diogo de Andrade Figueiredo, Eduardo Pugliese Pincelli, Flávio Eduardo Silva de Carvalho, H. Philip Schneider
Number of partners: 5
Number of lawyers: 18
Languages: Portuguese, English, German

Tax Litigation:
Eduardo Pugliese Pincelli, Cassio Sztokfisz, Flávio Eduardo Silva de Carvalho
Tax Planning: H. Philip Schneider, Diogo de Andrade Figueiredo

Firm Overview:
The firm is highly specialised in tax law advising national and foreign clients from a wide range of sectors. The firm is best known for its expertise on complex judicial and administrative tax litigation, tax consulting and tax planning. The team of specialists bring years of experience dealing with every single aspect of the intricate and challenging Brazilian tax system. The firm encourages innovative thinking to deliver creative solutions to meet clients’ needs, expectations and budget.

Main Areas of Practice:
Tax Litigation:
Tax Planning & Consulting: 50%

Tax Litigation:
The firm operates in both Administrative and Judicial Courts, including Higher Courts regarding tax assessment notices, writs of mandamus, declaratory actions, cancellation actions, tax enforcement actions, etc. Lawyers combine sound experience in judicial and administrative proceedings and are fully qualified to represent clients at the federal, state, federal district, and municipal levels. The firm has experience with repetitive appeals with the Superior Court of Justice (STJ) and with general repercussion appeals with the Federal Supreme Court (STF), representing companies and trade associations in the resolution of tax claims of domestic scope. The firm has won a leading case regarding the definition of inputs for the accrual of PIS and COFINS tax credits, one of the most significant tax discussions in Brazil. Following this emblematic victory, the firm’s client base of PIS/COFINS cases has increased in the past few years and currently amounts to about 2 billion reais. The firm’s successful track record has contributed to decisions by the Federal Supreme Court, and the Court has established an understanding that could be applied to other instances of the Brazilian Judiciary.

Tax Planning & Consulting:
The legal tax advisory team has vast experience in domestic and international tax consulting and tax planning matters. The services include preparing legal opinions to clarify the interpretation, the applicability of the tax legislation and the construction of corporate structures that allow legitimate tax savings. The work involves dealing with the State Treasury Offices and the Brazilian Federal Revenue Office to offset taxes, request refunds, organise contingencies for the issue of tax clearance certificates (CND); filing inquiries, obtaining the concession of special regimes and tax incentives, and advising clients on all measures to comply with tax requests. The firm designs tax strategies and structures that mitigate tax impact on clients’ businesses, with an allencompassing approach and business view.

International Work:
The firm’s tax advisory and tax planning team deals with several international taxation issues. International clients, generally multinational companies, with interests in Brazil demand advisory on cross-border transactions taxation, as well as ultra-high net worth private Brazilian clients, with assets abroad. The firm has also litigated against assessment notices involving the taxation of foreign source profits obtained by Brazilian companies.

ADM, Mosaic, Avon, Santander, Johnson&Johnson, Hypera, BRFoods, Cofco, General Motors, Itau, Whirlpool, Península Group, VBI Real Estate, UOL, Zurich Santander, Banco Votorantim