Tax
Litigation

Strategic tax litigation

Protecting your interests

We specialize in strategic tax litigation, advocating for our clients’ interests in navigating administrative and judicial proceedings at the municipal, state, and federal levels. Our approach to each case considers the unique circumstances of the client, their specific needs and risk profile, as well as the legal and financial implications for both the client and their stakeholders over time.

Our approach to litigation begins with strategic planning from the earliest stages of the dispute. This includes the careful management of audit procedures, reviewing documents that may impact the case outcome, and obtaining expert opinions and reports to support the strategy developed in collaboration with the client. We proactively pursue all available administrative avenues to minimize tax litigation and its negative consequences, addressing or reducing potential issues in advance, such as Debt Review Requests and Early Guarantee Offers.

We also guide clients in pursuing alternative dispute resolution methods and self-settlement options. We advise on defining and implementing consensual solutions in legal proceedings, such as negotiating judicial agreements. We negotiate and provide comprehensive support in reaching settlement agreements and participating in installment programs, amnesty initiatives, and self-regulation schemes, all aimed at resolving disputes more swiftly and cost-effectively.

Our tax litigation work includes:

Managing audit procedures at the municipal, state, and federal levels, and liaising with tax authorities through a constructive and cooperative dialogue.

Development of procedural strategies and management of all stages of complex administrative and judicial cases involving direct and indirect taxes at the municipal, state, and federal levels.

Representation before the Higher Courts (STJ and STF) on behalf of individuals, companies, industry groups, associations, and professional entities in leading cases, including as amicus curiae.

Analysis of case law and judge profiles to identify judicial trends and devise more effective strategies for litigation.

Monitoring legislation, precedents from the Higher Courts, and ongoing tax cases that could affect the client’s business, identifying opportunities to (i) preempt undue tax claims or (ii) recover undue amounts.

Comprehensive support to clients in resolving disputes, whether through Procedural Legal Agreements or Tax Settlement, including managing requests for the review of assessed payment capacity.

Assistance in pre-litigation administrative procedures (such as the Debt Review Request – PRDI and Early Guarantee Offer) to prevent disputes or reduce their immediate impacts, including those arising from the need to obtain a tax compliance certificate.

Full support in adhering to ensuring the proper compliance with installment programs, amnesty initiatives, and self-regulation schemes.

Strategic Tax Litigation

Our approach to tax litigation is grounded in a strategic and tailored approach, dedicated to defending our clients’ interests across all administrative and judicial stages. We prioritize thorough planning from the outset of the dispute, aiming to anticipate and minimize its negative consequences. Furthermore, we offer support in pursuing consensual solutions and negotiating settlements, ensuring an efficient and cost-effective resolution of conflicts.

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