Rafael Pandolfo

Practice Areas

Rafael Pandolfo is a founding partner of Rafael Pandolfo Advogados Associados and has worked in Tax Law for over 25 years, combining a solid academic and technical background with energy, creativity and strategic vision. With a PhD and a Master’s Degree in Tax Law from the Pontifical Catholic University of São Paulo (PUC-SP), he stood out as a judge at the Administrative Council for Tax Appeals (CARF - Conselho Administrativo de Recursos Fiscais), an experience that significantly contributes to the quality and consistency of his practice.

He currently coordinates the academic activities of the Brazilian Institute of Tax Studies (IBET - Instituto Brasileiro de Estudos Tributários) in Rio Grande do Sul, actively contributing to the training of professionals and the development of critical thinking in the tax area.

With extensive experience in developing and conducting defence strategies in administrative and judicial proceedings, his practice with CARF is especially strong in acting before local courts, particularly the Court of Justice of Rio Grande do Sul (TJRS), Regional Federal Appellate Court of the 4th Region (TRF4) and Superior Courts, being a national reference in highly complex tax litigation. He is also one of the most active voices in discussions on tax reform, participating in the formulation of proposals for the modernization of the Brazilian tax system.

His contribution goes beyond the legal practice: he collaborates in the preparation of legislative proposals, is a member of nationally recognized technical committees and leads tax planning projects, corporate restructurings and large-scale tax transactions, with a strong impact on the reality of all economic agents.

With a presence in various sectors of the economy, he is a consultant for the Federation of Trade in Goods and Services of the State of Rio Grande do Sul (Fecomércio-RS - Federação do Comércio de Bens e de Serviços do Estado do Rio Grande do Sul) and a member of the Technical Committee for Tax, Legal and Civil Affairs of the Federation of Industries of the State of Rio Grande do Sul (FIERGS - Federação das Indústrias do Estado do Rio Grande do Sul), reaffirming his commitment to developing efficient, safe legal solutions that are aligned with the demands of the business environment.

Professional Memberships

Former Statutory Advisor of the Administrative Council for Tax Appeals (CARF - Conselho Administrativo de Recursos Fiscais).

Coordinator of the Institute of Tax Studies (IBET) in Rio Grande do Sul

Member of the Technical Committee for Tax, Legal and Civil Affairs (Contec - Conselho Técnico de Assuntos Tributários, Legais e Cíveis) of the Federation of Industries of the State of Rio Grande do Sul (FIERGS - Federação das Indústrias do Estado do Rio Grande do Sul).

Advisor of the Federation of Trade in Goods and Services of the State of Rio Grande do Sul (Fecomércio-RS - Federação do Comércio de Bens e de Serviços do Estado do Rio Grande do Sul)

Member of the Institute of Tax Studies (IET - Instituto de Estudos Tributários), the Higher Education Foundation of Tax Law (FESDT - Fundação Escola Superior de Direito Tributário), the Institute of Tax Research (IPT - Instituto de Pesquisas Tributarias) and the Brazilian Academy of Tax Law (ABDT - Academia Brasileira de Direito Tributário).

Legal advisor and author of legal works in the tax area.

Publications

PANDOLFO, Rafael. Como ficou a não cumulatividade plena do IBS e da CBS na reforma tributária? (“What happened to the full non-cumulative nature of IBS and CBS in the tax reform?”) Opinion article in the Economy section of Estadão, on 07/05/2025. Available at: https://www.estadao.com.br/economia/nao-cumulatividade-ibs-cbs/?srsltid=AfmBOoqi2TbHzIB2ooCzqCyaOy13JHC_C_fSTZCJWLnP74qlYBIsOjhG

PANDOLFO, Rafael. Reforma tributária, saída de emergência e CNJ. (“Tax reform, emergency exit and CNJ”). Opinion article in Fausto Macedo's column in Estadão, on 29/04/2025. Available at: https://www.estadao.com.br/politica/blog-do-fausto-macedo/reforma-tributaria-saida-de-emergencia-e-cnj/?srsltid=AfmBOorjnHeRWARilTmG1ZYG26gdlk2nj1P4F1bGozF_31FvOikUN0qR

PANDOLFO, Rafael. Reconstrução do RS e tributação da retomada (“The reconstruction of Rio Grande do Sul and taxation of the recovery”). Opinion article in the Legislation column of Valor Econômico, on 29/07/2024. Available at: https://valor.globo.com/legislacao/coluna/reconstrucao-do-rs-e-tributacao-da-retomada.ghtml

PANDOLFO, Rafael. Jurisdição Constitucional Tributária: Reflexos nos Processos Administrativo e Judicial (“Constitutional Tax Jurisdiction: Reflections on Administrative and Judicial Proceedings”). 2nd ed. São Paulo: Noeses, 2020. v. 1. 320p.

PANDOLFO, Rafael, Taxation on the Economic Exploitation of Athlete Image Rights – How it Works (21 May 2016). Legal Consultant, 2016. Available at SSRN: https://ssrn.com/abstract=2854206.

PANDOLFO, Rafael. Fundamentos do Direito Processual Tributário (“Fundamentals of Tax Procedural Law”). São Paulo: Editora Saraiva, 2005. v. 01. 164p.

Work Highlights

Main areas of practice: tax litigation, tax consultancy, tax planning in domestic and international tax law, corporate taxation and taxation in mergers and acquisitions (M&A).

Leading lawyer in the development of defence strategies, both in administrative and judicial spheres, with active participation in trials before administrative and judicial courts and superior courts (Superior Court of Justice and Brazilian Supreme Court).

Languages Spoken

Portuguese (native).

English (fluent).

Education