Brazil

Partner

Machado Associados

São Paulo

+55 (11) 3819 4855

mbornia@machadoassociados.com.br

www.machadoassociados.com.br

Bar admissions: Brazilian Bar Association – São Paulo, Rio de Janeiro, and Brasília

Mauri Bórnia is a lawyer with 30 years of experience in the tax area with an emphasis on indirect taxes and tax litigation. He joined Machado Associados in 1999 and has been a partner of the firm since 2003.

With a highly specialised profile, Mauri is one of the partners in charge of the indirect taxes area at Machado Associados, serving domestic and multinational companies, taking part in several tax and corporate restructuring transactions and following up on new structures.

Brazilian Bar Association – São Paulo Chapter

Certified Public Accountant – São Paulo Chapter (CRC/SP)

Paulista Association of Tax Studies (APET)

Law Degree, Faculdade de Direito de Sorocaba, 2006

Postgraduate Studies in Tax Law – Universidade de Sorocaba, 1997

Business and Accounting School, Faculdade de Ciências Contábeis e Administrativas de Sorocaba, 1990

Restructuring, Transactions, Tax consulting, Customs, Supply Chains, and VAT

Consumer goods and services, Industrials, Pharma, Tech and Telecons, and Food and Beverage

Partner

Machado Associados

São Paulo

+55 (11) 3819 4855

rsilveira@machadoassociados.com.br

www.machadoassociados.com.br

Languages: Portuguese, English

Bar admissions: Brazilian Bar Association – São Paulo, Rio de Janeiro, and Brasília.

Mr. Silveira joined the firm in 1993 and was promoted to partner in the indirect tax area in 2005. He has a highly international profile and is one of the partners responsible for assisting multinational companies with businesses in Brazil and abroad, always with a strong indirect tax focus. Author of several articles and speaker in international events.

Ricardo's experience focuses on indirect tax (VAT), tax incentives, and custom's matters, including structuring tax efficient transactions.

Transactions, M&A, tax consulting, VAT, customs

Automotive, construction and materials, consumer goods and services, energy, industrials

Member of the Tax and Law Firm Management Committees of the International Bar Association (IBA)

Member of the Legal Committee of the American Chamber of Commerce in São Paulo (AMCHAM)

Director of Corporate Relations of the Brazilian Institute for Energy Law Studies (IBDE) – Biennium 2017-2019

Member of the Tax Commitee of the Center for the Study of Law Firms (CESA)

Postgraduate Degree in Tax Law – Pontifícia Universidade Católica de São Paulo (PUC/SP), 1997

Law Degree – Pontifícia Universidade Católica de São Paulo (PUC/SP), 1994

Partner

Machado Associados

São Paulo

+55 (11) 3819 4855

joliveira@machadoassociados.com.br

www.machadoassociados.com.br

Languages: Júlio is fluent in Portuguese and English

Bar admissions: Brazilian Bar Association – São Paulo, Rio de Janeiro, and Brasília

He has acted in many significant tax proceedings relating to direct and indirect tax as well as taxes levied on the payroll, in addition to rendering consulting services to large domestic and international companies. He is part of several committees and associations made up of companies that seek to improve the Brazilian tax system.

Júlio Oliveira has already acted as an examining professor on boards granting master's degrees at PUC/SP and Fundação Getúlio Vargas (FGV/SP), and also as judge of the Tax Administrative Court of the State of São Paulo (TIT). He is a tax law professor at PUC/SP and GV Law and professor of the tax law specialization course at Universidade de São Paulo (USP). Júlio has been acknowledged several times during his career, and was appointed as an outstanding lawyer in the Tax area in Brazil by national and international entities.

Dispute resolution, Tax consulting, VAT, Supply chains, Tax Litigation

Consumer goods and services, Food and beverage, Industrials, Pharma and life sciences, Tech and telecoms

Member of the Legal and Tax Committee of the British Chamber of Commerce and Industry in São Paulo

Adviser of the Center for Tax Studies (NEF) of the São Paulo Law School of Fundação Getúlio Vargas (FGV)

Júlio de Oliveira holds a Master's and a PhD degree in tax law from Pontifícia Universidade Católica de São Paulo (PUC/SP).

Partner

Ulhôa Canto

Rio de Janeiro

+55 21 3824-3227

gbrigagao@ulhoacanto.com.br

www.ulhoacanto.com.br

Languages: Portuguese and English

Bar admissions: Brazilian Bar Association – Rio de Janeiro and São Paulo

Gustavo Brigagão specializes in tax law with emphasis on administrative litigation and indirect taxation, dealing with matters related to industry, commerce and services sector, focused in the oil industry, telecommunication market, e-commerce, electric energy, information technology, clothing industry, professional entities, among others.

• Exclusive tax advisor regarding the staging and organization of the Fifa World Cup in Brazil.

• Provides tax advisory to major energy groups in Brazil (matters that involve more than 1 billion USD).

• Represented several companies that belong to the oil sector against tax assessments related to ICMS (State VAT). Such assessments combined were worth more than 500 million dollars (taxes and penalties) and the majority of them were cancelled.

• Provides tax advisory to major players of the clothing sector.

Technology, Litigation, Tax consulting, International tax advisory, VAT

Energy, Industrials, Oil and gas, Shipping, Tech and telecoms

President of the Brazilian Financial Law Association (ABDF). Member of the executive committee of the International Fiscal Association (IFA). President of the British Chamber of Commerce in Rio de Janeiro (BRITCHAM-RJ). Member of the General Council of the Brazilian Bar Association, branch of Rio de Janeiro (OAB/RJ).

Professor for the postgraduate course of Getúlio Vargas Foundation and, from 1993 until 2005, was professor of tax law in the graduate course of Cândido Mendes University.

Partner

Trouw & Fraga Advogados

Rio de Janeiro

+55(21)25049420

ffraga@tfslaw.com.br

www.tfslaw.com.br

Languages: Portuguese, English, Spanish

Bar admissions: OAB/RJ 117.404

He worked as a lawyer at PETROBRAS, 7th place in the entry examination competition.

He is author of several articles published in specialized reviews and a speaker at events in Brazil and abroad.

He received the Sacha Calmon Award for best thesis at the VIII Congress of Tax Law.

• French oil and gas company; implementation of the company's cost sharing policy regarding the parent company in France and its subsidiary in Uruguay.

• Brazilian telecom company; only in the current year, we filed over 50 lawsuits arguing the unconstitutionality of the TFF (local tax levied by Brazilian Municipalities).

• American oil and gas company; complete analysis of the Brazilian company's tax situation to report for the parent company located in USA.

Business model optimisation, restructuring, cost-sharing arrangements, litigation, tax consulting

Energy, food and beverage, industrials, oil and gas, tech and telecoms

Director of the Tax Debates Group of Rio de Janeiro (GDT-RIO).

Director of the Brazilian Financial Law Association (ABDF).

Member of the Practice Council of the LL.M. in International Taxation Program of the New York University (NYU).

Professor of the LL.M. in Tax Law of Getúlio Vargas Foundation (FGV).

Graduation in Law, Pontifical Catholic University of Rio de Janeiro, 2003.

Postgraduation in Tax Law, University of Salamanca, 2005.

Postgraduation in Gas and Oil, Brazilian Oil Institute, Center of Advanced Studies and Oil Research from the University of the State of Rio de Janeiro (UERJ) and from the Campos School of Law, 2005.

PhD, Autonomous University of Lisbon, 2017/2018.