Patrícia Linhares

Private pensions; tax law; pension fund taxation; pension plan structuring and management; regulatory advice; administrative and judicial litigation; corporate governance; compliance; data protection; corporate and contractual advice; arbitration and mediation.

Founding and managing partner of Linhares & Advogados Associados since 2006, a law firm focused on advising medium-sized and large companies in the industry, commerce and services sectors, financial institutions and private pension entities.

Before founding the firm, Patricia worked as a tax lawyer at Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga Advogados, in São Paulo and Salvador, from 2003 to 2006, advising on taxation of financial and capital markets transactions, banking products, insurance, international taxation, private pension taxation, tax planning and tax litigation.

Alongside her legal practice, Patricia has developed a longstanding academic career. She has been a university professor for 20 years, teaching tax law, financial law and supplementary pension law in undergraduate and postgraduate programmes. She has taught at institutions including Faculdade Baiana de Direito, UCSAL, IDS, UniAbrapp, JusPodivm and FGV-SP/GVLaw.

She holds a master’s degree in Public Law from PUC-SP, with a dissertation on income tax and the taxation of private pension plans, and a law degree from Universidade Mackenzie.

Member of the Brazilian Bar Association, admitted in Bahia and São Paulo. Member of the Brazilian Institute of Tax Law (IBDT). Certified board member and associate of the Brazilian Institute of Corporate Governance (IBGC). Arbitrator at CAMES – Câmara de Mediação e Arbitragem Especializada.

Former member of the Fiscal Council of OABPrev-SP, the multipatrocinated pension fund of the São Paulo section of the Brazilian Bar Association and CAASP. President of the Special Data Protection Committee of the Bahia section of the Brazilian Bar Association from 2022 to 2024 and for the 2025-2028 term.

Former member of the International Association of Privacy Professionals (IAPP) and of the Forum Empresarial LGPD until 2022. Member of the Editorial Board of the Revista do Centro de Estudos Jurídicos – Celso Barroso Leite.

Author of two books: *Previdência Complementar – Lei Complementar nº 109/2001* (Juspodivm, 2009) and *Tributação dos Investimentos em Previdência Complementar Privada – Fundos de Pensão, PGBL, VGBL, FAPI e Outros* (Quartier Latin, 2008).

Her published book chapters include: “Reflexões sobre o Tema 1224 do STJ às contribuições extraordinárias de planos de previdência complementar” in *Previdência Complementar – Papel Transformador na Inclusão e Proteção Social* (ABRAPP, 2025); “Arquitetura do Planejamento Sucessório” in *Previdência Complementar: Um Resgate à Natureza Jurídica e seus Efeitos Diante do Óbito do Participante* (Fórum, 2021); “Os Impactos da Reforma da Previdência e da Covid-19 sobre a Previdência Complementar Fechada” (ABRAPP, 2020); “Impactos da Lei Geral de Proteção de Dados para as EFPC” (ABRAPP, 2019); “A Previdência Complementar Aberta do Servidor Público” (Juspodivm, 2019); “Cobrança de PIS e COFINS sobre os Ingressos Financeiros Registrados pelas EFPC” (APEP, 2015); “Questões Tributárias das Entidades e dos Planos de Previdência Complementar” (ABRAPP/ICSS/SINDAPP, 2009); and “Tratamento Tributário Aplicado: Patrocinadores, Participantes e Ativos Financeiros dos Planos de Previdência Complementar” (ABRAPP, 2006).

Patricia is a lawyer, professor, author and speaker with a strong academic and professional background in tax law and private pensions. She has been a university professor for 20 years, teaching tax law, financial law and supplementary pension law in undergraduate and postgraduate programmes in Brazil.

She holds a master’s degree in Public Law from PUC-SP, a post-MBA in Board Administration from Saint Paul Escola de Negócios, an extension programme at the European School of Management and Technology in Germany, an extension course in Big Data and Artificial Intelligence from FIA-SP, and legal English training from Cambridge Law Studio at Girton College, University of Cambridge.

She has been recognised by Análise Editorial as one of Brazil’s Most Admired Lawyers, regionally and nationally, in the 2017, 2020, 2021, 2022, 2023, 2024 and 2025/2026 editions. She was also the winner of the 8th PREVIC Monograph Award in 2024.

Patricia’s experience combines more than two decades of legal practice, academic work and sector-specific involvement in tax law and private pensions. She started her career working at a leading full-service law firm, advising on taxation of financial and capital markets transactions, banking products, international taxation and private pension taxation, which provided the foundation for her later specialisation in the legal and tax framework applicable to pension funds and supplementary pension plans.

Since founding Linhares & Advogados Associados in 2006, she has built a multidisciplinary practice advising pension entities, financial institutions and corporate clients on complex matters involving pension plan structuring, fund taxation, regulatory compliance, governance, administrative proceedings and strategic litigation.

Her professional work is closely connected to her academic profile. She holds a master’s degree focused on income tax and private pension plans, has taught tax, financial and supplementary pension law for 20 years, and regularly contributes to specialised publications, seminars and legal debates. This combination of advisory practice, litigation experience and academic production gives her a particularly strong technical profile in matters involving the intersection of private pensions, taxation and governance.

Universidade Mackenzie

Bachelors in Law

1998 - 2002

PUC/SP

Master in Law

2003 - 2006

8º Premio de Monografia

PREVIC (MInistério da Previdência Social)

2024

Patricia has significant experience advising clients in the private pensions sector, particularly closed pension entities, pension funds, corporate sponsors and stakeholders involved in the structuring, management and supervision of supplementary pension arrangements.

Her sector expertise includes pension plan design, amendments to benefit plan regulations, adhesion terms, contracts with participants and suppliers, legal feasibility of new pension products and services, pension fund taxation, regulatory compliance, plan management, governance, legal risk assessments, administrative inspections and disputes involving pension entities.

She also advises clients in financial services, banking, industry, commerce and services, combining her private pensions expertise with tax, corporate, governance, compliance and litigation experience.

Brazil