Gabriela Jajah

Practice Areas

Tax

Career

Professional with over 15 years of experience in administrative and judicial tax litigation, with a strong background in the strategic management of tax case portfolios.

She provides tax advisory services to national and international clients across various economic sectors, including financial, industrial, and service industries.

In recent years, she has been consistently recognized for her excellence in the tax field by renowned national and international legal rankings.

Professional Memberships

Member of the Brazilian Bar Association

Publications

· JAJAH, Gabriela Miziara. The Liability of Third Parties in Tax Enforcement Proceedings and the IDPJ. Jota, São Paulo, March 21, 2023.

· JAJAH, Gabriela Miziara. The Necessary and Ongoing Relief of Payroll Tax Burden. Âmbito Jurídico, São Paulo, September 6, 2022.

· JAJAH, Gabriela Miziara. The Federal Revenue’s Use of Asset and Rights Listings and the Violation of Efficiency and Reasonableness Principles. Estadão, São Paulo, April 11, 2022. Blog do Fausto.

· JAJAH, Gabriela Miziara. Will the Tax War Really End? Valor Econômico, São Paulo, November 18, 2019.

· JAJAH, Gabriela Miziara; CLARKE, Daniel Franco. While the Tax Reform Does Not Come. Jota, São Paulo, January 14, 2019.

· JAJAH, Gabriela Miziara. Asset Confusion in Tax Matters. Valor Econômico, São Paulo, May 5, 2017.

· JAJAH, Gabriela Miziara. Who Benefits from the Demonization of Refis? Estadão, São Paulo, April 19, 2017.

· JAJAH, Gabriela Miziara; CLARKE, Daniel Franco. Risks of Merging the PIS and Cofins Tax Regimes. Valor Econômico, São Paulo, March 27, 2017.

· ROSA, Arthur; OLIVON, Beatriz. Government Reduces Social Contribution Credits. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, January 17, 2023.

· AGUIAR, Adriana. São Paulo City Approves Taxpayer Code. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, January 20, 2020.

· AGUIAR, Adriana. São Paulo City Approves Taxpayer Code. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, January 19, 2020.

· IGNÁCIO, Laura. Confaz Publishes Rule on Undue Tax Benefits. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, March 16, 2018.

· FRIAS, Maria Cristina. Change in Tax Authority Approach Increased Assessments, Say Lawyers. Comments: Gabriela Miziara Jajah. Folha de São Paulo, São Paulo, February 22, 2018.

· IGNÁCIO, Laura. Federal Revenue Regulates Debt Consolidation in PRT. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, December 13, 2017.

· IGNÁCIO, Laura. Tax Authorities Require Registration of Payments for Software Licensing. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, October 18, 2017.

· IGNÁCIO, Laura. Federal Revenue Ignores STJ Ruling and Continues to Tax One-Third Vacation Bonus. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, August 23, 2017.

· IGNÁCIO, Laura. São Paulo City Hall Opens Tax Debt Installment Program. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, July 6, 2017.

· IGNÁCIO, Laura. Tax Authorities Deny PIS and Cofins Credits on International Freight. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, January 25, 2017.

· IGNÁCIO, Laura. São Paulo Tax Authority Begins Electronic Notifications to Companies. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, August 23, 2016.

· AGUIAR, Adriana. Federal Revenue Changes Interpretation on PIS and Cofins Credits. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, June 10, 2016.

· OLIVON, Beatriz. Companies Cannot Deduct Aneel Fines from IR and CSLL. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, April 19, 2016.

· OLIVON, Beatriz. STJ Prohibits Use of Interest on Equity to Pay Cofins. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, April 13, 2016.

· BACELO, Joice. Rio Conditions ICMS Amendments on Tax Authority’s Approval. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, January 22, 2016.

· BACELO, Joice. State of Rio Creates New Tax and Changes ITCMD Rates. Comments: Gabriela Miziara Jajah. Valor Econômico, São Paulo, January 5, 2016.

Clients

Atos Group, Unify and Kellogg

Industry Sector Expertise

Food Industry and General Product Manufacturers

Technology services and software licensing

Construction and Infrastructure

Expert in these Jurisdictions

Brazil

Languages Spoken

Portuguese, English and Spanish

Work Highlights

First Case: Restructuring operations for a client engaged in manufacturing to order, to maximize tax benefits related to ICMS (ICMS due on the importation of parts and components and ICMS due on local market operations) and IPI due to investments in research and development in the production process.

Second Case: Review of the taxation of all international intra-group transactions (provision of services, cost sharing agreements, among others) to ensure correct tax treatment and optimize the tax burden (analysis of applicable treaties to avoid double taxation and the benefits provided for in local legislation).

Third Case: Assessment of the legal possibilities for using accumulated ICMS credits, considering the projects under development by the client, as well as ways to speed up the transfer of credits to third parties.

Awards

Education