Brazil

Av Matarazzo, 1400

Torre Milano, 16th Floor

São Paulo, SP 05001-903

Brazil

Tel: +55 11 3879 2800

Email: gileno.barreto@br.pwc.com

Website: pwc.com/taxcontroversy

Gileno Barreto is a partner at PwC in the São Paulo legal services practice and he is co-leader of PwC Brazil's tax controversy and dispute resolution network.

Gileno was appointed as counsellor to the third section of the federal taxation court in 2006 and is vice-president of his collegiate of the Brazilian Federal Tax Administrative Court (CARF). He is also a member of superior instance of judgment in the CARF.

He works or worked on federal lawsuits related to the social contributions (PIS, COFINS and INSS), excise tax (IPI); import and export taxes; customs duties; tax on financial operations and income tax (IRPJ and CSLL), among others.

Gileno has more than 10 years of experience in tax litigation and controversy resolution in the administrative and judicial courts related to federal, state and municipal levels. He also has more than 20 years of experience in tax consulting activities in Brazil and five years in accounting and auditing.

He gained broad experience of the legislative process inside the National Congress, including working on policy proposals, the national budget, internal commissions, budget execution, and national accounting procedures during four years as Chief of the Deputy Office.

Gileno has experience of regulatory and administrative law and in tax planning projects rendered to national and multinational companies, particularly those in construction, banking, chemicals, forest and paper, energy and utilities, mining and oil, and education. Gileno is a consultant to several agencies and publicly owned companies: including federal and state companies in the electric energy sector and in the banking and financial services sector, the Brazilian Energy Agency (ANEEL), the Transportation Agency (ANTT) and Telecommunications Agency (ANATEL).

He was also the technical coordinator of the Brazilian Customs Modernisation Plan (PMAB) rendered to the Brazilian Federal Revenue Services.

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 M. 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 a member of several committees and associations made up of companies that seek to improve the Brazilian tax system.

Júlio has 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 is professor of the tax law specialisation course at Universidade de São Paulo (USP).

He was nominated 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).

He recently co-authored the book Tributação e Desenvolvimento – Homenagem ao Prof. Aires Barreto and has co-authored the following books: Processo Tributário Analítico (Editora Noeses); IPI – Aspectos Jurídicos Relevantes (Editora Quartier Latin); 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); ISS – Lei Complementar 116/2003 (MP EDITORA); Direito Tributário e os Conceitos de Direito Privado (Editora Noeses).

Av Almirante Barroso, 52 / 31º floor

Rio de Janeiro

20031-000

Brazil

Tel: +55 21 3824 6033

Fax: +55 21 3824 6090

Email: mpf@bmalaw.com.br

Website: www.bmalaw.com.br

Mauricio Pereira Faro is an associate of Barbosa Müssnich & Aragão (BM&A). He joined the firm in June 2007.

He is a lecturer in the continuing education programme at Cândido Mendes University, Universidade Federal Fluminense – UFF, and Getúlio Vargas Foundation – RJ. He has been a judging counsel at the Federal Administrative Council of Tax Appeals – CARF since 2010.

He is a member of the Brazilian Bar Association, Rio de Janeiro Section (OAB-RJ); president of the Special Commission on Tax Matters for the Rio de Janeiro Section of the Brazilian Bar Association and a member of the Special Commission on Tax Matters for the Federal Council of the Brazilian Bar Association; and has been on the council of the Brazilian Bar Association since 2010.

Mauricio has a master of law degree from the Gama Filho University – UGF, a specialisation in tax law from the Brazilian Institute of Tax Studies – IBET (2004) and a law degree from Rio de Janeiro State University -UERJ (2001).

Mauricio is co-author of the following books: Aspectos Polêmicos do Agronegócio (Editora Castro Lopes), Pis e Cofins à Luz da Jurisprudência do CARF Vol I (MP EDITORA), PIS e Cofins à luz da jurisprudência do CARF Vol II (MP Editora), Aspectos Tributários relacionados à Indústria do Petróleo e Gás (MP Editora), Curso de Direito Tributário (Quartier Latin), Curso de Direito Tributário Brasileiro (Quartier Latin), Direito Tributário, Societário e a Reforma da Lei das S/A – Vol I (Quartier Latin) and Direito Tributário, Societário e a Reforma da Lei das S/A Vol II (Quartier Latin).

He speaks Portuguese and English.

Av Brig Faria Lima, 1656 – 11º andar

01451-918 – São Paulo / SP

Brazil

Tel: +55 11 3819 4855

Fax: +55 11 3819 5322

Email: dmaya@machadoassociados.com.br

Website: www.machadoassociados.com.br

Daniel Lacasa Maya is a partner in tax litigation at Machado Associados where he has worked in the tax advisory and litigation area since 1994. He has a degree from Pontifícia Universidade Católica de São Paulo.

During his career, he has handled judicial and administrative litigation in matters of federal, state and municipal taxes, including advising on cases before the Federal Supreme Court, presenting oral arguments before the Full Session of the Court, the Superior Court of Justice, and the 1st and 2nd panels of the Court.

He has also presented oral arguments before the Administrative Council of Tax Appeals (CARF), the former Taxpayers' Council, and before panels of the High Court of Tax Appeals.

He is a professor of postgraduate courses in tax law at Fundação Getúlio Vargas and of Instituto Internacional de Ciências Sociais, and he has also given classes in postgraduate courses in tax law at COGEAE – PUC/SP and the Instituto Brasileiro de Estudos Tributários.

Av Matarazzo, 1400

Torre Milano, 16th Floor

São Paulo, SP 05001-903

Brazil

Tel: +55 11 3879 2800

Email: fernando.loeser@br.pwc.com

Website: pwc.com/taxcontroversy

Fernando Loeser is a partner at Loeser & Portela Advogados, a member of the PwC tax and legal network.

Fernando joined PwC in 1987 and began working in tax consultancy and corporate law.

He joined Loeser & Portela Advogados in 1989 as a senior lawyer and became a manager in 1992, before being admitted as a partner in 1997.

Fernando is a member of the São Paulo and Minas Gerais chapters of the Brazilian Bar Association (OAB) and is also a member of the American Chamber of Commerce. He holds a bachelor of law degree from the Law School of the Pontificia Universidade Catolica de São Paulo – PUC/SP (1991).

Fernando has experience in corporate law, M&A and antitrust law and provides legal counselling on M&A; spin-off processes; due diligence processes; incorporation of subsidiary companies in Brazil; drafting of articles of association; corporate amendments; transfer of shares agreements and shareholder's agreements.

He also provides legal counselling on public law and compliance, administrative agreements and governmental assignments, concessions and privatisations of public services.

In addition to experience in tax consultation and litigation, Fernando has worked in the area of employment law, including litigation on employment rights.

He has also written chapters and articles in various books and journals and is fluent in Portuguese, English and Spanish.

Av Nove de Julho, 5109 – 4º

São Paulo, SP – 01407-905

Brazil

Tel: +55 11 3245-8429

Email: mmatsunaga@kpmg.com.br

Website: www.kpmg.com/BR

Marcos Matsunaga is a tax and legal partner and leads KPMG's tax resolution disputes and controversies services in Brazil.

Matsunaga is also a member of the steering committee of KPMG's global tax dispute resolution and controversies network.

He has wide experience in tax law across different industry sectors, and focuses on providing advice for the prevention and resolution of tax disputes, and advice about direct taxes, due diligence and tax planning.

Marcos joined KPMG in 1997 and has been a KPMG partner since 2008.

Marcos has a bachelor's 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 was named as one of Brazil's tax controversy leaders by International Tax Review in 2012.

Av. Matarazzo, 1400

Torre Torino

São Paulo, SP 05001-903

Brazil

Tel: +55 11 3674 2800

Email: durval.portela@br.pwc.com

Website: pwc.com/taxcontroversy

Durval Portela is a lawyer who graduated from the Law School of the Universidade Federal da Bahia.

He holds a master's degree in economic law at the same university and obtained a post-graduate qualification in tax law at Pontifícia Universidade Católica de São Paulo.

Durval is a regular member of the Paulista Centre of Tax Studies – NUPET, Brazilian Tax Law Institute; the Brazilian Financial Law Association and the International Fiscal Association.

He is PwC's partner in charge of Brazilian international tax services (ITS) and tax controversy and dispute resolution (TCDR) practices and has 25 years of experience practising in tax litigation and tax consulting.