Practice Area
Tax
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Tax: Non-contentious and Controversy
Our tax team advises companies and investors throughout the full lifecycle of their tax matters, from planning and structuring transactions to handling audits, reviews and complex litigation. We provide an integrated service that combines tax advisory and controversy, with a strategic approach focused on managing risk, supporting compliance and informing our clients' business decisions.
We advise on the tax planning and structuring of domestic and cross-border operations, including corporate reorganizations, financings, investments and long-term projects. Our work focuses on assessing tax implications, identifying risks and designing efficient structures aligned with our clients’ business strategy.
We support clients in meeting their recurring tax obligations and in the correct application of applicable regulations. Our team reviews relevant tax positions, assists in the preparation and documentation of key requirements, and helps design internal processes that promote certainty and reduce exposure to potential contingencies.
We participate in mergers and acquisitions, joint ventures, divestments and financing transactions, evaluating the tax impact of each proposed structure. We work closely with corporate, financial and regulatory teams to ensure that every transaction is implemented with sound, well-documented and sustainable tax design.
We advise on the application of double-taxation treaties, permanent establishment rules and withholding obligations in cross-border operations. Our work includes analyzing investment structures, capital flows and intercompany payments, offering solutions that comply with applicable standards and provide long-term certainty.
We represent taxpayers in audits, desk reviews and on-site inspections initiated by the tax authorities. We assist at every stage—from responding to information requests to addressing preliminary findings—ensuring positions are well supported and risks are properly managed.
We design and implement defense strategies in administrative proceedings, including refund requests, administrative remedies and other mechanisms for dialogue with the authorities. Our approach combines solid legal arguments with practical alternatives to mitigate risk and protect cash flow.
We litigate tax disputes before administrative and judicial courts, challenging assessments, penalties and other actions that impact our clients’ operations. Our team focuses on building technically robust cases supported by legal criteria and aligned with the taxpayer’s business objectives.
We assist in negotiating and resolving complex controversies with tax authorities, assessing risk scenarios, economic exposure and available regularization alternatives. We participate in strategic discussions and settlement processes to achieve solutions that provide certainty and allow clients to focus on their core business activities.

The team comprises a highly skilled group of professionals, including public accountants, who provide independent tax advice and regularly support other practice areas of the Firm, particularly in the context of complex cross-border mergers and acquisitions transactions.
In addition, our Firm is distinguished by the wide range of matters of any nature and complexity in which we have participated, as well as by the professionalism of our multidisciplinary team and its ability to provide different solution alternatives in complex tax disputes and litigation to our clients.