Brazil

Managing partner and the head of the tax department of LRI Advogados

Lautenschlager, Romeiro e Iwamizu Advogados

São Paulo

+55 11 2126 4600

gcm@lrilaw.com.br

www.lrilaw.com.br

Languages: Portuguese, English

Gilberto de Castro Moreira Jr is a managing partner and the head of the tax department of LRI Advogados. He is based in São Paulo.

Gilberto has been practicing law in São Paulo since 1990. Gilberto's practice is focused on tax law (litigation, advisory and planning).

• Nominated for the 5th, 6th and 7th editions of International Tax Review's Tax Controversy Leaders Guide (2015, 2016 and 2017)

• Nominated as the 2016 and 2018 Leading Tax Advisor of the Year, Brazil (Acquisition International Magazine); as the 2017 and 2018 Tax Planning

• Lawyer of the Year – Brazil (Finance Monthly Magazine); as the 2018 Tax Lawyer of the year – Brazil (International Advisory Experts)

Gilberto's practice is focused on tax law (litigation, advisory and planning).

He is the coordinator of the LLM in international taxation at the Brazilian Institute of Tax Law (IBDT), an arbitrator of the Association of European Chambers of Commerce and Industry's mediation and arbitration chamber (CAE), a member of tax litigation committee of the São Paulo Bar Association, of the Brazilian Institute of Tax Law (IBDT), of the scientific council of the Tax Law Association of São Paulo (APET), of the International Association of Tax Judges (IATJ) and a sitting member of the Lawyers' Institute of São Paulo (IASP). Former councillor of the 3rd Section of the Administrative Court of Tax Appeals (CARF), former tax law professor of the Mackenzie Presbyterian University

Gilberto holds a JD degree from the University of São Paulo (USP) and a PhD degree in economics and financial law from the University of São Paulo. Gilberto's practice is focused on tax law (litigation, advisory and planning).

Partner

Tauil & Chequer in Association with Mayer Brown

São Paulo

+55 11 2504 4671

cgrisi@mayerbrown.com

www.tauilchequer.com.br

Languages: Portuguese and English

Bar admissions: Brazil

Celso has more than 15 years of experience in practicing tax and has advised major domestic and international corporations. His experience includes drafting legal opinions and structuring investments and M&A transactions across Latin America. He has secured a number of Special Tax Regimes and Tax Rulings for a variety of industries.

Celso represented Dutch asset management company APG, CPPIB, Australian fund First State Super (FSS) and Singaporean sovereign wealth fund GIC establishing a US$700 million fund to target Brazilian logistics assets and industrial real estate. Celso has also helped CPPIB signing a joint venture agreement with Brazilian real estate investor Cyrela. Finally, Celso helped Metrofit signing with Goldman Sachs an agreement to invest US$ 200 million on self storage business.

Business model optimisation, Technology services, Cross-border project management, Restructuring, Cost-sharing arrangements, Transactions, M&A, Corporate taxes, Cryptocurrency, Audit defence, Pre-litigation, Litigation, Tax consulting, International tax advisory

Member of the consulting Board of the Brazilian Association of Financial Law ("ABDF"), related to the International Fiscal Association ("IFA").Member of Transactional Taxation Network ("TTN"), related to the International Bureau of Fiscal Documentation ("IBFD").Member of Tax Committee of the International Bar Association ("IBA").

University of São Paulo, LLM on International Trade Law. University of Michigan Law School, LLM on International Tax Law. Catholic University of São Paulo – PUC/SP, Bachelor of Law (JD equivalent). The Hague Academy of International Law, Course on International Trade. University of California, Berkeley, Orientation in the US Legal System.

Partner

Loeser, Blanchet e Hadad - Advogados

São Paulo

+55 11 3879 2800

fernando.loeser@lpadv.com.br

lpadv.com.br

Fernando Loeser is a partner at Loeser, Blanchet e Hadad Advogados, the correspondent law firm of PwC Legal in Brazil.

Fernando joined PwC in 1987, when he started working with tax consultancy and corporate law. He joined Loeser, Blanchet e Hadad Advogados (formerly Loeser e Portela Advogados) in 1989 as senior lawyer and became a manager in 1992 before being admitted as a partner five years later, in 1997. Member of the São Paulo, Rio de Janeiro, Brasília, Bahia and Minas Gerais chapters of the Brazilian Bar Association (OAB), and also member of several chambers of commerce in Brazil. Fernando holds a bachelor's degree in law from the Law School of PUC/SP (1991).

Fernando has more than 30 years' experience in tax litigation and controversy resolution in the administrative and judicial courts related to federal, state and city taxes at all levels as well as tax consultancy services. Fernando is also experienced in corporate law, M&A and antitrust law.

During his career he has provided legal advice in several M&A, spin-offs; due diligence and structuring and restructuring processes, as well as in the incorporation of subsidiary companies in Brazil; drafting of articles of association, corporate amendments, transfer of shares agreements and shareholder's agreements.

Fernando has also coordinated several projects related to the review of procedures adopted by national and multinational companies in compliance with Brazilian tax laws and regulations. He has also provided tax advice in structuring and restructuring projects carried out by national and multinational companies. His clients include companies in the construction, retail, mining and oil, and education sectors.

He writes chapters and articles in various books and journals and is a native speaker in Portuguese as well as being fluent in English and Spanish.

Partner

Tauil & Chequer in association with Mayer Brown

São Paulo

+55 11 2540 4626

amartins@mayerbrown.com.br

tauilchequer.com.br

Languages: Portuguese (native) and English

Bar admissions: Rio de Janeiro, São Paulo, Recife

Ana Luiza Martins is a partner in the tax practice of Tauil & Chequer Advogados in the São Paulo office. She has a large experience in tax consulting and litigation before the Brazilian Administrative and Judicial Courts. Among her clients are national and international companies pertaining to various industry sectors.

• Handling representative judicial tax litigation for a multinational company on the application of the Brazil-Italy DTT to certain services agreements (multimillion-euro discussion)

• Handling multimillion-dollar administrative discussions on State VAT taxation for multinationals in São Paulo

• Handling discussions with Brazilian States on tax VAT benefits for multinational clients (LC 160/2017)

• Assisting multinationals as to recent changes to the Manaus Free Trade Zone benefits

Cost-sharing arrangements, Corporate taxes, Technology, Litigation, Tax consulting

Consumer goods and services, Energy, Food and beverage, Industrials, Utilities

Brazilian Bar Association

International Bar Association

New York University – LLM in International Taxation, 2004

Pontifícia Universidade Católica do Rio de Janeiro – PUC/RJ, Bachelor in Law (equivalent to JD), 1998.

Latin America Leader, Tax Dispute Resolution & Controversy

KPMG

São Paulo

+55 11 39408069

mmatsunaga@kpmg.com.br

Languages: Portuguese, English, Spanish

Bar admissions: São Paulo

Marcos Matsunaga is a tax and legal partner and leads KPMG's tax dispute resolution and controversy services in Brazil. In addition to his national role, Marcos is also the LATAM leader within KPMG International's Global Tax Dispute Resolution & Controversy Services network. Matsunaga joined KPMG Brazil in 1998 and has been a partner since 2008

Marcos has represented several national and international corporate clients before the administrative and judicial tax courts in Brazil, dealing with complex controversial matters. He has a wide range of experience in tax law and different industry sectors, with a focus on advising on the prevention and resolution of tax disputes, from the pre-dispute phase through examinations and appeals. Due to his international role, he has coordinated and participated in a number of cross-border projects throughout Latin America.

Audit defence, Dispute resolution, Pre-litigation, Litigation, Controversy management, Tax consulting, M&A, R&D tax incentives, Corporate tax.

Automotive, Financial services, Industrials, Insurance, Tech and telecoms

Member of the Brazilian Bar Association, GETAP (Grupo de Estudos Tributário Aplicados) and an advisory board member of ENACTUS Brasil

• Bachelor's degree in law from Pontifícia Universidade Católica de São Paulo – PUC/SP – 1999

• Specialization degree in tax law from Fundação Getúlio Vargas

• Master degree in tax law from Pontifícia Universidade Católica de São Paulo – PUC/SP (ongoing)

Partner

Severo, Vaz, Ferreira de Moura, Olympio, Megozzi e Carvalho Advogados

São Paulo

+55 1138424040

enzo.megozzi@severovaz.com.br

www.severovaz.com.br

Bar admissions: Brazil

Corporate taxes, Technology, Dispute resolution, Litigation, Tax consulting

Agriculture, Consumer goods and services, Energy, Mining, Pharma and life sciences, Shipping, Tech and telecoms

Partner

Rocca, Stahl, Zveibil & Marquesi

São Paulo (SP), Rio de Janeiro (RJ), Indaiatuba (SP), Itajaí (SC) and Brasília (DF).

+55 11 3218 7288

eduardo@rszm.com.br

www.rszm.com.br

Languages: Portuguese, English and Spanish

As a partner of the recognized law office Rocca, Stahl, Zveibil & Marquesi, which provides services in the form of consultancy and legal advice, Eduardo Rocca has worked for several and large-scale multinational companies in coordination of strategic work to reduce tax liabilities/tributaries.

Tax Consulting, Tax Litigation and International Tax Advice

Basic Industries; Trade; Services; Agribusiness; Aviation; International Trade; Communications and Telecommunications; Energy, Oil and Gas; Sports; Information Technology; Transportation and Logistics, among others.

Member of the Brazilian Bar Association (OAB); the Lawyers Association of São Paulo (AASP); and the Association for Promoting the Technology and Use of Tax Incentives.

• Lawyer graduated from Centro Universitário das Faculdades Metropolitanas Unidas (FMU/SP)

• Post-graduate degree in Tax Law from Pontifícia Universidade Católica de São Paulo (PUC/SP).

• Specialist in Tax Accouting by FGVLaw.

Partner

Rocca Stahl Zveibil & Marquesi

São Paulo, Rio de Janeiro (RJ), Indaiatuba (SP), Itajaí (SC) and Brasília (DF)

+55 11 3218 7288

stahl@rszm.com.br

www.rszm.com.br

Languages: Portuguese, English and Spanish

As a partner of the recognized law office Rocca Stahl Zveibil & Marquesi, which provides services in the form of consultancy and legal advice, Sidney Stahl has extensive experience in providing legal advice to major national and international companies and is notoriously renowned for his academic dedication.

• He was Professor of Constitutional Law at the Pontifícia Universidade Católica de São Paulo (PUC), under the supervision of Prof. Michel Temer, current president of the Federative Republic of Brazil. Also taught at the Escola Superior de Magistratura de Mato Grosso do Sul.

• Ex-Counselor of the Administrative Council of Fiscal Resources of the Ministry of Finance (CARF)

Tax Consulting, tax litigation and International Tax Advice

Agriculture, Aviation, Energy, Oil and gas, Tech and telecoms, Transport

Member of Brazilian Bar Association (OAB); the Lawyers Association of São Paulo (AASP); the Brazilian Association of Tax Law (ABDT); the Brazilian Association of Tax Consultants (ABCT); the Brazilian Academy of Tax Law (ABDT); and the Scientific Committee of the São Paulo Association of Tax Studies (APET).

Lawyer graduated from Pontifícia Universidade de São Paulo (PUC); Doctoral Degree in Tax Law from PUC; Post-graduate lato sensu in Accounting and Financial Management from Fundação Getúlio Vargas (FGV).

Partner

Tauil & Chequer Advogados in association with Mayer Brown

Rio de Janeiro

+ 55 21 2127 4213

itauil@mayerbrown.com

www.mayerbrown.com

Languages: Portuguese, English

Bar admissions: Brazil

Ivan Tauil is the founding partner and Head of the tax law practice of Tauil & Chequer Advogados in association with Mayer Brown and serves on Mayer Brown's Partnership Board. He has extensive experience in local and international taxation.

• Represented a foreign group in the tax restructuring of this group that had just been acquired under a transaction worth more than $3 billion.

• Represented a Brazilian client in connection with drafting the statement of defence for a tax fine involving more than $1.1 billion.

• Represented a German industrial group with revenues in excess of $4 billion in the tax structuring of its business in Brazil.

Restructuring, Corporate taxes, Tax consulting, International tax advisory

Energy, Real estate

Chairman, Oil & Gas Committee of the Brazilian Bar Association, Rio de Janeiro Chapter; Director, Brazilian Tax Law Academy; Member, Urban Land Institute (ULI); Member, Association for Real Estate Project Development in Brazil (ADIT); Former Chairman, Science Board of the Brazilian Academy of Tax Law; Member, Editorial Board of Revista Tributária e de Finanças Públicas, edited by Revista dos Tribunais; Member, Brazilian Institute of Constitutional Law (Instituto Brasileiro de Direito Constitucional); Member, American Chamber of Commerce (AmCham); Member, International Bar Association; Member, International Fiscal Association; Member, Brazilian Finance Law Association

Universidade de Coimbra, Specialization degree in European Law, 1996; Pontifícia Universidade Católica do Rio de Janeiro, LLM in Constitutional Law and Theory of the State, 1989; Universidade Federal Fluminense, Bachelor of Law (JD equivalent), 1987; Universidade Federal do Rio de Janeiro, Bachelor of Social Science, 1987.

Senior Partner

André Teixeira & Associados Law Firm

Rio de Janeiro and São Paulo

+55 21 2203 0330 and +55 11 30688933

andre.teixeira@at.adv.br

www.at.adv.br

Languages: English, Portuguese, Spanish

Bar admissions: Brazil, Portugal

Senior Partner of André Teixeira & Associados Law Firm, a Brazilian law firm with branches in Rio de Janeiro and São Paulo; specialising in energy taxation, especially oil and gas and renewables.

Strong performance in corporate law and corporate governance.

Restructuring, M&A, Corporate taxes, Litigation, Tax consulting

Automotive, Energy, Food and beverage, Natural resources, Oil and gas

ABDF (Associação Brasileira de Direito Financeiro); IFA (International Fiscal Association);

IBA (International Bar Association);

AIPN (Association of International Petroleum Negotiators).

Founder partner of Oil & Gas Law Alliance.

Rio de Janeiro Federal University

Bachelor of Laws – LLB

Tax & Corporate

Dates graduation 1987 – 1991

Candido Mendes University (1995)

Postgraduate Diploma

Corporate Law

Lisbon University (2017)

Postgraduate Diploma

Corporate Governance

Partner

Tauil & Chequer in association with Mayer Brown LLP

Rio de Janeiro

+55 21 21274229

etelles@mayerbrown.com

www.tauilechequer.com.br

Languages: Portuguese, English, French

Bar admissions: Brazil

Eduardo Telles focuses on tax dispute resolution as well as projects and general tax consulting. He has extensive experience working with oil & gas, manufacturing and services industries and is now developing a digital taxation practice.

• Advised a FRSU provider in structuring its business in Brazil. Provided contractual tax protection and specific doing business for Brazil

• Advises a Multinational Chemical Company in its biggest tax case in Brazil, helping developing all strategy including factual background research and knowledge of administrative and judicial system.

• Advises one of the biggest Oilfield Services Companies in the world in all its tax cases for more than 10 years, generating over USD 100 MM in savings

Business model optimisation, Technology, Audit support, Litigation, Tax consulting

Consumer goods and services, Energy, Industrials, Oil and gas

Brazilian Bar Association

Coordinator of Post Graduate Tax Courses at Fundação Getúlio Vargas – FGV Rio

Journalism – Bachelor Degree, Rio de Janeiro State University, 1994

Law – Bachelor Degree, Rio de Janeiro Federal University, 1996

Master in Tax Law, Candido Mendes University, 2004