Brazil

PwC

Av. Francisco Matarazzo, 1400

Torre Milano, 15th Floor

São Paulo, SP 05001-903

Brazil

Tel: +55 11 3879 2800

Email: gileno.barreto@br.pwc.com

Website: pwc.com.br

Gileno G Barreto is a partner at Loeser e Portela Advogados, the correspondent law firm of PwC in Brazil, and he is the leader of PwC Brazil's tax controversy and dispute resolution network.

Gileno has more than 10 years' experience in tax litigation and controversy resolution in the administrative and judicial courts related to federal, state and city taxes at all levels, and more than 20 years acting in tax consulting activities in Brazil, as well as five years in accounting audit.

He gained broad experience of legislative procedures at the National Congress including advising on the drafting of laws, the national budget, internal commissions, budget execution and national accounting procedures among other tax policy issues and legislative activities.

During his career as a tax adviser, he has coordinated several projects related to the review of procedures adopted by national and multinational companies in compliance with Brazilian tax laws and regulations. He also has provided tax advice in structuring and restructuring projects carried out by national and multinational companies. His client portfolio includes companies in the construction, financials, insurance, chemical, forest and paper, energy and utilities, mining and oil, and education sectors. Gileno is also responsible for restructurings and merger and acquisition projects on behalf of both public and private companies.

Appointed as counsellor of the Brazilian Federal Tax Administrative Council (CARF) in 2006, to its 3rd Section, Gileno served until January 2015 as vice-president of his collegiate.

Gileno is also a specialist in corporate restructuring transactions for clients in a variety of business areas: M&A, spin-off and mergers processes; legal due diligence processes; experience in agribusiness including tax litigation to several ethanol companies and consultancy regarding land property acquisition.

He is an adviser to several Brazilian agencies and public-owned companies: electric energy companies (Eletrobras) and to the Brazilian Energy Agency (ANEEL), the Transportation Agency (ANTT) and public-owned banks like Banco do Brasil and Caixa Economica Federal. Gileno is the project technical coordinator of the Brazilian customs modernisation plan (PMAB) rendered to the Brazilian Federal Revenue Services (RFB). He also now acts as a European Commission consultant.

The meeting of his experience in accounting audit, tax audit, government relations, business administration and in settlement of disputes relating to tax law, regulatory law and anticorruption, anti-bribery and anti-money laundry laws result in a unique expertise in compliance and corporate governance, both in legal matters and regarding other aspects of the corporate lifecycle, such as in business management processes.

Gileno graduated from the Law School of UNICEUB in Brasilia-DF, and holds an MBA from the Fundação Getúlio Vargas – FGV and is post-graduated in international tax law (IBDT). He is a member of the Brazilian Bar Association, chapters of Federal District, São Paulo, Rio de Janeiro, Minas Gerais, Bahia and Sergipe.

Lautenschlager, Romeiro e Iwamizu Advogados

Av. Paulista, 1.842 – 22º andar – Torre Norte

São Paulo – SP

01310-200

Brazil

Tel: +55 11 2126 4600

Fax: +55 11 2126 4601

Email: gcm@lrilaw.com.br

Website: www.lrilaw.com.br

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. He 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). 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 and former member of the Ethics Court and tax law committee of São Paulo Bar Association. He is the author of the book Bitributação Internacional e Elementos de Conexão (International Double Taxation and Connection Elements); coordinator and co-author of the books Direito Tributário Internacional (International Tax Law) and PIS e COFINS à luz da jurisprudência do CARF (vols. 1 and 2) (PIS and COFINS taxes under the CARF precedents). He is also the co-author of 22 books and several articles addressing tax matters.

Gilberto was nominated for the 5th and 6th editions of International Tax Review's Tax Controversy Leaders guide (2015 and 2016). He was also nominated as the 2016 Leading Tax Advisor of the Year, Brazil (Acquisition International Magazine); as the 2017 Tax Planning – Lawyer of the Year – Brazil (Finance Monthly Magazine) and as the 2017 Tax Lawyer of the year – Brazil (International Advisory Experts).

Tauil & Chequer Advogados in association with Mayer Brown

Av. Juscelino Kubitschek 1455 – 5º, 6º e 7º andares

Vila Nova Conceição – 04543-011

São Paulo

Brazil

Tel: +55 11 2504 4671

Fax: +55 11 97613 0573

Email: CGrisi@mayerbrown.com

Website: www.mayerbrown.com

Celso Grisi is a partner in the tax practice of Tauil & Chequer Advogados in Association with Mayer Brown at the São Paulo office. Celso has more than 18 years of experience in practicing tax litigation and providing tax advice and has advised major domestic and international corporations. His experience includes drafting memorandums and legal opinions involving the analysis of tax merits, study and development of topics for discussing tax levying, as well as structuring investments and M&A transactions across the country. Also, Celso has secured a number of special tax regimes and tax rulings for a variety of industries, including the chemical and automotive sectors. Celso is a judge and vice-president of the 8th Chamber at the State of São Paulo Tribunal of Administrative Taxes, a specialised administrative tribunal on indirect tax litigation.

Celso has published a number of articles in specialised law journals in Brazil and has taught corporate tax law at the Fundação Instituto de Administração of the University of São Paulo and Mackenzie University Law School.

PwC

Av. Francisco Matarazzo, 1400

Torre Milano, 15th Floor

São Paulo, SP 05001-903

Brazil

Tel: +55 11 3879 2800

Email:

fernando.loeser@br.pwc.com

fernando.loeser@lpadv.com.br

Website: pwc.com.br; lpadv.com.br

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

Fernando joined PwC in 1987, when he started working with tax consultancy and corporate law. He joined Loeser & Portela Advogados (formerly Castro, Campos & Associados – 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 the Pontifical Catholic University of São Paulo – PUC/SP (1991).

Fernando has more than 24 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, mergers and acquisitions and antitrust law.

During his career he has provided legal advice in several M&As, 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 shareholders' 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 has been also responsible for several projects related to compliance with anti-bribery and anti-money laundering laws (FCPA, Brazilian FCPA, UK Bribery Act) by Brazilian companies, conducting and/or overseeing investigation procedures, as well as reporting procedures.

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.

Tauil & Chequer Advogados in association with Mayer Brown

Av. Juscelino Kubitschek 1455 – 5º, 6º e 7º andares

Vila Nova Conceição – 04543-011

São Paulo

Brazil

Tel: +55 11 2504 4626

Fax: +55 21 2127 4211

Email: amartins@mayerbrown.com

Website: www.mayerbrown.com

Ana Luiza Martins is a partner in the tax practice of Tauil & Chequer Advogados in the São Paulo office, with an LLM in international taxation by the New York University School of Law. Ana Luiza has a large amount of 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, such as consumer goods, hospitality and leisure, goods and services, infrastructure, pharmaceutics and technology (telecom).

Ana Luiza started her career in 1997 as a tax litigation associate in a prestigious litigation boutique based in Rio de Janeiro. In 2000, she joined Veirano Advogados to work with Guido Vinci, a founding partner of the tax department of the said firm. In 2007, she joined Campos Mello Advogados associated to DLA Piper, as a senior associate focused in tax litigation and strategic consulting, becoming a partner in the São Paulo office in January 2011. In October 2015, Ana Luiza joined Tauil & Chequer as a partner, also based in São Paulo. During her career, Ana Luiza has represented multinational companies, mainly North American, Italian and French, and prominent Brazilian companies, including those listed in the stock market, having sponsored causes and argued before the highest Brazilian courts and tax administrative bodies, including STF (Federal Supreme Court), STJ (Superior Court of Justice) and CARF (Federal Administrative Tax Court).

KPMG in Brazil

Rua Arquiteto Olavo Redig de Campos, 105, 12º andar

Edifício EZ Tower – Torre A

CEP 04711-904 – São Paulo, SP

Brazil

Direct: +55 11 3940 8429

Email: mmatsunaga@kpmg.com.br

Website: www.kpmg.com.br

Marcos H M 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 and controversy services network. He has a wide range of experience in tax law and different industry sectors, with a focus on advisory for prevention and resolution of tax disputes, from the pre-dispute phase (voluntary disclosures, private letter rulings, tax risks assessment) through examinations and appeals.

Marcos represents several national and international corporate clients before administrative and judicial tax courts in Brazil, dealing with complex controversial matters related to direct and indirect taxes, domestic and international tax issues. His clients include financial institutions, insurance companies, international pension funds, and industrial and agribusiness companies.

Due to his international role, Marcos has coordinated and participated in a number of cross-border projects in the Latin America region, dealing with multi-jurisdictional teams, which has given him an outstanding work experience in mergers and acquisitions, transfer pricing, corporate restructuring and research and development tax incentives.

Marcos joined KPMG Brazil in 1998 and has been a partner since 2008. He has a bachelor's degree in law from the Pontifical Catholic University of São Paulo (PUC/SP) and a specialisation degree in tax law from Getúlio Vargas Foundation (GVLaw). He is member of the Brazilian Bar Association, GETAP (Grupo de Estudos Tributário Aplicados) and a board member of ENACTUS Brasil. Marcos has been named by International Tax Review as one of the tax controversy leaders in Brazil since 2012 and has been acknowledged by Análise Advocacia 500 as one of the most admired Brazilian tax lawyers in 2014, 2015 and 2016.

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

Rua Fidêncio Ramos, 160, cj. 1501

Vila Olímpia

São Paulo/SP – CEP 04551-010

Brazil

Tel: +55 11 3842 4040

Email: enzo.megozzi@severovaz.com.br

Website: www.severovaz.com.br

Enzo Megozzi is a lawyer with more than 20 years of practice in the tax litigation field.

Enzo has taken part in major Brazilian law firms and, as of 2015, is a partner of Severo, Vaz, Ferreira de Moura, Olympio e Megozzi Advogados.

He graduated at Mackenzie Presbyterian University, attended a post-graduate course at the Brazilian Institute of Tax Law and at the Brazilian Institute of Tax Studies (IBET). He is also a member of the Brazilian Institute of Tax Law.

Enzo has acted as a professor at the post-graduate course at Mackenzie Presbyterian University and in several other institutions throughout the country. He has also joined many lectures on tax law as a key speaker. Enzo has been nominated by specialised publications as one of the most admired Brazilian attorneys-at-law in his field of practice.

Tauil & Chequer Advogados in association with Mayer Brown

Rua Teixeira de Freitas, 31 – 9º andar

20021-350 Centro

Rio de Janeiro

Brazil

Tel: + 55 21 2127 4213

Fax: + 55 21 2127 4211

Email: itauil@mayerbrown.com

Website: www.mayerbrown.com

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. He is also the author of several articles and is often a lecturer at a number of legal and corporate events in Brazil and abroad.

Ivan holds an LLM in constitutional law and theory of the state from PUC-RJ. He is the chairman of the oil and gas committee of the Brazilian Bar Association, Rio de Janeiro Chapter, director of the Brazilian Tax Law Academy, and a member of the Brazilian Finance Law Association, the International Fiscal Association and the International Bar Association. In addition, Ivan is also a member of the editorial board of Revista Tributária e de Finanças Públicas – Ed. Revista dos Tribunais.

In 2016, both Chambers Global and Chambers Latin America recognised him as one of the "leaders in their field" for his legal work in the tax sector.

Tauil & Chequer Advogados in association with Mayer Brown

Rio de Janeiro:

Rua Teixeira de Freitas 31 – 9º andar

20021-350 Centro

Rio de Janeiro

Brazil

Tel: +55 21 2127 4229

Fax: +55 21 2127 4211

São Paulo:

Av. Juscelino Kubitschek 1455 – 5º, 6º e 7º andares

Vila Nova Conceição – 04543-011

São Paulo

Brazil

Tel: +55 11 2504 4210

Fax: +55 11 2504 4211

Email: etelles@mayerbrown.com

Website: www.mayerbrown.com

Eduardo Maccari Telles is a partner in the Rio de Janeiro office of Tauil & Chequer Advogados. Eduardo concentrates his practice on trial, litigation and arbitration, tax and administrative law. He represents national and foreign companies and governmental institutions, assisting them in all types of dispute resolution for tax, civil, labour, intellectual property and environmental cases as well as tax and labour consulting. Eduardo also has experience in energy and insurance litigation and being responsible for coordinating the firm's Brazil litigation practice.

Since 2000, he has also served as a state attorney in the Attorney's Office of the State of Rio de Janeiro. His other professional assignments have included work as a tax attorney with the National Institute of Social Security (1998-2000), as a legal counsellor with Rangel, Penna da Rocha & Daiha Associated Attorneys (2000-2006), as external counsel for the Brazilian Institute of Municipal Administration (2000-2020) and as Treasury representative on the Taxpayer Council of the State of Rio de Janeiro (2004). Eduardo is also the coordinator of Fundação Getúlio Vargas (FGV) post-graduate tax courses in tax litigation, constitutional tax, real estate and oil and gas taxation and is a professor of post-graduate tax courses at the Court of Rio Janeiro Judge's School (EMERJ), Fundação Getúlio Vargas (FGV) and the Federal University of Rio de Janeiro (UFF).