Tax decisions affect how a Brazilian investment is funded, how it trades and how value moves within an international group. We advise European companies on the Brazilian legal aspects of these decisions, connecting the intended commercial model with tax analysis and documentation. The work may concern a new operation, an acquisition, a recurring transaction or a dispute with the authorities. We coordinate with the company’s accounting team and overseas advisers so that assumptions used in Brazil are visible to the people approving the wider structure.
What we do
- Assessment of tax implications of investment and financing structures.
- Review of related-party transactions and transfer pricing documentation needs.
- Tax due diligence connected with acquisitions and reorganisations.
- Analysis of contracts, cross-border payments and proposed operating models.
- Assessment of consumption tax reform effects on contracts and processes.
- Advice on tax controversies and coordination with accounting teams.
Experience in this practice
An overview of our work, described without identifying clients or individual transactions.
- Tax advice on international trading, investment structures and transactions involving European groups and their Brazilian companies.
- Assessment of related-party operations, transfer pricing and the interaction between Brazilian obligations and the group’s tax policies.
- Support on tax questions arising from acquisitions, business reorganisations, contractual arrangements and the day-to-day operation of the company.
Why it matters for European companies
Brazil’s OECD-aligned transfer pricing framework under Law 14,596/2023 has been mandatory since 2024. The IBS/CBS consumption tax reform introduces a further transition that businesses should assess against their activities and implementation timetable. These are distinct workstreams: a group pricing policy does not by itself address Brazilian compliance or the operational effects of consumption taxes. The applicable obligations and timing require a case-specific review.
How we organise the mandate
The first discussion identifies the decision to be made, the companies involved and the timetable. We review the available documents before proposing a defined scope, deliverables and fees. The responsible partner coordinates contributions from the relevant practices, so that a recommendation can be considered against its operational consequences. Reporting distinguishes decisions required from the client, information still missing and work completed. When another jurisdiction is involved, we agree how the Brazilian work will connect with the group’s advisers abroad.
Preparing the first discussion
Useful starting material includes the group structure, the Brazilian entity’s details, existing agreements and a short explanation of the commercial objective. Please indicate any live deadline and the people authorised to give instructions. The initial contact need not contain confidential case documents or sensitive personal information. We can agree an appropriate channel for exchanging the supporting material after identifying the parties and the scope of the request.