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: www.pwc.com/taxcontroversy

Gileno 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 the judicial courts related to federal, state and city taxes at all levels, and more than 20 years of experience 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 legislation, the national budget, internal commissions, budget execution and national accounting procedures among other tax policy issues and legislative activities.

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.

During his career as a tax adviser and lawyer, he has coordinated several projects related to the review of procedures adopted by national and multinational enterprises in compliance with Brazilian tax laws and regulations. He is an adviser to several Brazilian agencies and public-owned companies and banks.

Gileno was the project technical coordinator of the Brazilian customs modernisation plan (PMAB) rendered to the Brazilian Federal Revenue Services (RFB) and now acts as a European Commission tax consultant. He also provides tax advice in structuring and restructuring projects carried out by national and multinational enterprises and is responsible for M&A projects on behalf of both public and private companies including legal due diligences and consultancy regarding land property acquisition. His client portfolio includes companies in the construction, financials, insurance, chemical, forest and paper, energy and utilities, mining and oil, and education sectors.

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 anti-corruption, anti-bribery and anti-money laundering 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, holds an MBA from the Fundação Getúlio Vargas – FGV and an LLM 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.

Carvalho e Natale Advogados 

Tel: +55 11 5186 1268

Email: jcarvalhojr@carvalhoenatale.com.br

José de Carvalho Jr is an international business tax and corporate consulting partner in Carvalho e Natale Advogados, with 24 years of experience in corporate and tax.

He specialises in corporate income taxes, foreign capital legislation, corporate law, corporate reorganisations and international tax planning structures, as well as direct taxes and tax controversy. 

He leads the legal practice and is also the Brazilian tax controversy team leader. Jose has been involved in several international tax engagements.

Jose has bachelor degrees in accounting (1982), economics (1984) and law (1989), and is registered in the Regional Accounting Council (CRC), Regional Economics Council (CRE), and in the Brazilian Bar Association (OAB).

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 partner and the head of the tax department of Lautenschlager, Romeiro e Iwamizu. He is based in São Paulo.

Gilberto has been practising law in São Paulo since 1990. He holds a JD degree from the University of São Paulo and a PhD degree in economic and financial law from the University of São Paulo. Gilberto's practice is focused on tax law (litigation, advisory and planning).

He is an arbitrator of the EUROCHAMBERS' Mediation and Arbitration Chamber (CAE), a member of the tax law and tax litigation committees 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 councilor 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 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' (volumes 1, 2 and 3) (PIS and COFINS taxes under the CARF precedents). In total, he has co-authored 21 books and written several articles addressing tax matters.

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: www.pwc.com/taxcontroversy

Fernando Loeser is a partner at Loeser e Portela 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 & Portela Advogados (formerly Castro, Campos & Associados – Advogados) in 1989 as a senior lawyer and became a manager in 1992 before being admitted as a partner five years later, in 1997.

He is a 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 bachelors 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, 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 agreement.

Fernando has also coordinated several projects related to the review of procedures adopted by national and multinational enterprises 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 enterprises. 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 Kubitschek1455 – 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 in the São Paulo office of Tauil & Chequer Advogados.

Ana Luiza has vast experience in tax consulting and litigation. Among her clients are major national and international enterprises from various industries, including consumer goods, hospitality and leisure, infrastructure, pharmaceuticals, technology and telecommunications.

She started her career in 1997 as a member of the tax practice of Gouvêa Vieira Advogados. In 2000, she joined the tax department of Veirano Advogados to spur the tax litigation practice. In 2007, she joined Campos Mello Advogados as a senior associate focusing on tax litigation and strategic tax consulting, becoming a partner in January 2011. In October 2015, Ana Luiza joined Tauil & Chequer as a tax partner based in the firm's São Paulo office.

Throughout her career, Ana Luiza has represented several major multinational enterprises, most of which are in the US, Italy and France, as well as prominent stock exchange-listed companies of Brazil. She has argued cases for these clients before the highest Brazilian courts, including the STF (Brazil's Supreme Court), the STJ (Brazil's highest court for non-constitutional matters) and the CARF (the highest administrative tax court of the Brazilian federal administration).

KPMG

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 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 wide 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 risk assessments) 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 among the Latin America region, dealing with multi-jurisdictional teams, which has given him outstanding experience in mergers and acquisitions, transfer pricing, corporate restructuring and R&D tax incentives.

Marcos joined KPMG Brazil in 1998 and has been a partner since 2008. He has a bachelors degree in law from Pontifícia Universidade Católica de São Paulo – PUC/SP and a specialisation degree in tax law from Fundação Getúlio Vargas – GVLaw. He is member of the Brazilian Bar Association, GETAP (Grupo de Estudos Tributário Aplicados) and NEF/FGV (Núcleo de Estudos Fiscais). Marcos has been named by International Tax Review as one of the tax controversy leaders in Brazil since 2012 and has been recognised by Análise Advocacia 500 as one of the most admired Brazilian tax lawyers in 2014 and 2015.

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 Freitas31 – 9º andar

20021-350 Centro

Rio de Janeiro

Brazil

Tel: +55 21 2127 4229

Fax: +55 21 2127 4211

São Paulo:

Av. Juscelino Kubitschek1455 – 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 and São Paulo offices of Tauil & Chequer Advogados. Eduardo is responsible for coordinating the firm's Brazil tax controversy practice and focuses on tax controversy, litigation and arbitration, tax consulting and administrative law.

He represents national and foreign companies, as well as governmental institutions, and he assists them in all types of dispute resolution for tax cases and with tax consulting.

Eduardo has a lot of previous experience in energy, civil, labour, intellectual property, environmental and insurance litigation. He has a master's degree in tax law and coordinates the post graduate programmes of tax controversy, constitutional tax and oil and gas taxation at Fundação Getúlio Vargas. He is also a guest professor in post graduate programmes at others universities in Rio de Janeiro, like Catholic University (PUC), IBMEC and Cândido Mendes and also at the Judge's School of Rio de Janeiro.

Since 2000, Eduardo 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 (1998-00), as external counsel for the Brazilian Institute of Municipal Administration (2000-04) and as treasury representative on the Taxpayer Council of the State of Rio de Janeiro (2004).

PwC

Avenida Francisco Matarazzo, 1400

Torre Milano, 15th Floor

São Paulo, SP 05001-903

Brazil

Tel: + 55 11 3879 2800

Email: paulo.vital@lpadv.com.br

Website: www.pwc.com/taxcontroversy

Paulo Vital is a tax director with 20 years' experience and strong expertise in tax controversy and dispute resolution matters before the administrative and judicial courts, comprising both direct and indirect taxes. Paulo is a specialist in various sectors of industry, including commerce and technology companies, advising and defending both publicly and privately held companies in highly complex cases related to tax planning. Paulo is also experienced in providing legal advice on tax matters.

Paulo graduated in 1998 from the Mackenzie University and holds a master's degree in tax law from the Pontifical Catholic University of São Paulo.

Paulo is a native speaker in Portuguese and is also fluent in English