Rafael Santos Borin

Practice Areas

Rafael Santos Borin is a managing partner at Rafael Pandolfo Advogados Associados and, for over 25 years, has worked with strategic vision and high technical precision in coordinating the Tax and Business Advisory Areas. His career stands out for conducting sophisticated tax planning, structuring special regimes and working in highly complex administrative litigation.

With solid experience in tax consultancy, he leads strategies aimed at credit recovery, risk mitigation and the generation of competitive advantages with legal certainty. Recognized as one of the best experts in tax reform, he actively participates in discussions on the topic, both in technical and institutional instances. He is a frequent speaker at national-level events, conferences and seminars, in addition to giving workshops and in-company training, contributing significantly to the construction of a more modern and efficient tax system.

Present in several segments of the economy, he is director of tax affairs for the Union of Accounting, Advisory, Expertise, Information and Research Services Companies of the State of Rio Grande do Sul (SESCON-RS - Sindicato das Empresas de Serviços Contábeis, Assessoramento, Perícias Informações e Pesquisas do Estado do Rio Grande do Sul) and advisor 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), in addition to working with several other union entities, such as the Wholesale Trade Union for Porto Alegre and the State of Rio Grande do Sul (Sindiatacadistas-RS) and the Union of Plastic Material Industries in the State of RS (Sinplast-RS).

Professional Memberships

Director of Tax Affairs at the Union of Accounting, Advisory, Expertise, Information and Research Services Companies of the State of Rio Grande do Sul (SESCON-RS - Sindicato das Empresas de Serviços Contábeis, Assessoramento, Perícias, Informações e Pesquisas do Estado do Rio Grande do Sul).

Tax 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 Board of Directors at the Institute of Tax Studies (IET - Instituto de Estudos Tributários).

Full Member of the Higher Education Foundation of Tax Law (FESDT - Fundação Escola Superior de Direito Tributário).

Former Judge with the Administrative Tax Appeals Court (TARF - Tribunal Administrativo de Recursos Fiscais).

Professor of specialization programs at the Pontifical Catholic University of Rio Grande do Sul (PUCRS - Pontifícia Universidade Católica do Rio Grande do Sul) and the Institute of Tax Studies (IET - Instituto de Estudos Tributários).

Consultant for trade unions, such as the Wholesale Trade Union for Porto Alegre and the State of Rio Grande do Sul (Sindiatacadistas-RS) and the Union of Plastic Material Industries in the State of RS (Sinplast-RS).

Publications

BORIN, Rafael S.; NICHELE, Rafael. Curso Avançado de Processo Administrativo Tributário (“Advanced Course in Tax Administrative Proceedings”). Porto Alegre: Livraria do Advogado, 2012.

BORIN, Rafael. O split payment no novo cenário tributário (“Split payment in the new tax scenario”). Opinion article in the Legislation column of Valor Econômico, on 08/11/2024. Available at: https://valor.globo.com/legislacao/coluna/o-split-payment-no-novo-cenario-tributario.ghtml

Work Highlights

Structuring tax planning and corporate reorganizations with a focus on tax efficiency and legal compliance.

Strategic consultancy to business entities on issues of tax, legislative and regulatory impact.

Technical-oriented practice in relevant administrative proceedings before the Administrative Council for Tax Appeals (CARF - Conselho Administrativo de Recursos Fiscais) and the Administrative Tax Appeals Court (TARF - Tribunal Administrativo de Recursos Fiscais).

Specialist in direct and indirect taxes.

Active participation in legislative proceedings and institutional negotiations involving tax benefits and specific regimes.

Consulting and teaching on tax reform topics.

Languages Spoken

Portuguese (native).

English (fluent).

Education