Brazil

Machado Associados Advogados e Consultores

Av. Brig. Faria Lima, 1656 – 11º andar

01451-918 – São Paulo / SP

Brazil

Tel: +55 11 3819 4855

Fax: +55 11 3819 5322

Email: mbornia@machadoassociados.com.br

Website: www.machadoassociados.com.br

Mauri Bórnia is a lawyer with 30 years of experience in the tax area with emphasis on indirect taxes and tax litigation. He joined Machado Associados in 1999 and has been a partner of the firm since 2003. Before this, he worked as a tax consultant at IOB – Informações Objetivas e Publicações Jurídicas, one of the largest legal consulting firms in Brazil and has also worked at an industrial company, where he started his career in the tax area.

He graduated in Law from Faculdade de Direito de Sorocaba and concluded his postgraduate studies in tax law at UNISO – Universidade de Sorocaba. He is also an accountant, having graduated from Faculdade de Ciências Contábeis e Administrativas de Sorocaba.

He is a member of the Brazilian Bar Association – São Paulo Section (OAB/SP), the Regional Accounting Council – São Paulo Section (CRC/SP) and of Associação Paulista de Estudos Tributários (APET).

Mauri was a postgraduate professor in tax law for a course held by Trevisan Escola de Negócios and by Centro de Extensão Universitária of Instituto Internacional de Ciências Sociais (CEU/IICS). He also gives several lectures in this area of law, especially on social contributions, taxes levied on consumption of goods and services and foreign trade taxation.

Throughout his career, he has authored several articles and given interviews in specialised magazines and newspapers.

His academic and professional background provides him a wider view of all aspects related to the application of the tax law in defence of clients' interests, mainly as to the correct application of the law in the tax and accounting organisation of their companies.

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 new structures.

Machado Associados

Av. Brig. Faria Lima, 1656, 11º andar

01451-918 – São Paulo / SP

Brazil

Tel: +55 11 3819 4855

Fax: +55 11 3819 5322

Email: rsilveira@machadoassociados.com.br

Website: www.machadoassociados.com.br

Ricardo Marletti Debatin da Silveira is a lawyer with 22 years of experience in the tax area, with emphasis on indirect taxes and tax litigation. He joined Machado Associados in 1993 and has been a partner of the indirect tax practice since 2005.

He graduated in law from Pontifícia Universidade Católica de São Paulo (PUC/SP) in 1994, where he also concluded his postgraduate studies in tax law in 1997.

He is the director of institutional relations at the Brazilian Institute of Energy Law Studies (IBDE), after holding the position of chairman of the Institute's advisory board for four years. IBDE is an entity that has taken an important role in the study of legal matters in the Brazilian energy segment, with special focus on oil, gas, electric energy and renewable sources.

Ricardo is a member of the Brazilian Bar Association in São Paulo (OAB/SP), the Tax Committee of the International Bar Association (IBA), the Legal Committee of the American Chamber of Commerce in São Paulo (AMCHAM), and of the International Chamber of Commerce (ICC).

During his career, he has authored several articles and given interviews in specialised magazines, books and newspapers.

Ricardo has a high international profile and is one of the partners responsible for serving multinational companies with business and investments in Brazil, especially assisting foreign clients to understand and deal with tax, customs and corporate issues in Brazil, and heading due diligence work in mergers and acquisitions transactions.

The experience from several years of consultancy services and from many significant cases shared with international law firms around the world provides him with a client-oriented perspective of taxes and tax litigation, especially on highly complex cases.

Ricardo is fluent in Portuguese and English.

Machado Associados Advogados e Consultores

Av. Brig. Faria Lima, 1656 – 11º andar

01451-918 – São Paulo / SP

Brazil

Tel: +55 11 3819 4855

Fax: +55 11 3819 5322

Email: joliveira@machadoassociados.com.br

Website: www.machadoassociados.com.br

Júlio de Oliveira is a partner of the law firm Machado Associados, with master's and PhD degrees in tax law from Pontifícia Universidade Católica de São Paulo (PUC/SP).

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 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 specialisation course at Universidade de São Paulo (USP). He was appointed as one of the most respected tax lawyers in Brazil by the Os Mais Admirados do Direito yearbook in 2006, 2008, 2009 and 2010, and nominated as one of the 30 outstanding Brazilian tax lawyers in the corporate area since 2010 by Who's Who Legal.

He is the author of the books Internet e Competência Tributária (Editora Dialética) and O Princípio da Legalidade e sua aplicabilidade ao IPI e ao ICMS (Quartier Latin). Júlio Oliveira has recently co-authored the book Tributação: Democracia e Liberdade: em Homenagem à Ministra Denise Arruda Martins. He has also co-authored the following books: O direito tributário entre a forma e o conteúdo (Editora Noeses); Tributação do setor industrial (Editora Saraiva); Tributação e Desenvolvimento – Homenagem ao Prof. Aires Barreto; ISS – Lei Complementar 116/2003 (Editora Juruá); Comentários ao Código Tributário Nacional (Editora MP); Curso de Especialização em Direito Tributário: Estudos Analíticos em Homenagem a Paulo de Barros Carvalho (Editora Forense); Interpretação e Estado de Direito (Editora Noeses); ICMS – Questões Fundamentais (Editora MP); Questões Fundamentais – IPI (Editora MP); Grandes Questões Atuais do Direito Tributário – 10° Volume (Editora Dialética); Sistema Tributário Brasileiro e a Crise Atual (Editora Noeses); Estudos em Homenagem a José Eduardo Monteiro de Barros – Direito Tributário (MP Editora); Revista Direito Tributário Atual (Revista dos Tribunais); Tributação Empresarial (Saraiva – Série GVLaw); Direito Tributário: Homenagem a Paulo de Barros Carvalho (Quartier Latin); Direito Tributário e os Conceitos de Direito Privado (Editora Noeses); and others.

Deloitte Brazil

Rua Jose Guerra, 127

Sao Paulo 04719-030

Brazil

Tel: +55 11 5186 1002

Email: dolopes@deloitte.com

Website: www.deloitte.com

Douglas Lopes, Deloitte Brazil, is an indirect tax partner based in Sao Paulo, with more than 20 years of experience in indirect tax matters. He has participated in several projects involving review procedures related to indirect and custom taxes, revision of tax burdens, due diligence, spin-offs, consolidation of companies and tax technology. Douglas is the partner in charge of the indirect tax practice in the Brazil office. He has provided courses and seminars on tax related issues, given interviews and written articles for several magazines and newspapers.

Douglas is a member of the Regional Accounting Council. He earned a degree in accounting and law. He speaks Portuguese and English.

Deloitte Brazil

Av Presidente Wilson, 231 Andar 22

Rio de Janeiro 20030-021

Brazil

Tel: +55 21 3981 0451

Email: lrezende@deloitte.com

Website: www.deloitte.com

Luiz Fernando Rezende Gomes began his career in taxation and corporate law in 1997, specialising in review procedures related to indirect and custom taxes, revision of tax burdens, due diligence and tax technology. He has participated in several projects involving corporate restructuring, tax planning and implementation of tax related systems. His advises clients on matters of indirect tax, customs law, international tax, tax and corporate consulting and tax planning, among others. Luiz serves clients across a broad spectrum of industries in the energy and resources, especially in the oil and gas and mining, and in the manufacturing and leisure industries. Luiz is the lead tax partner for mining in Brazil and also in charge of the Tax Compliance and BPS practice in the Rio de Janeiro Office. He has provided courses and seminars on tax related issues, given interviews and written articles for several magazines and newspapers.

Luiz earned a degree in law from the Federal University of Rio de Janeiro – UFRJ and an MBA in finance from IBMEC. He speaks Portuguese and English.