Tributary

Tributary

• Ardanaz Society of Lawyers has in the area of taxation one of its main bases and is ready to deal with the most complex issues.
• The law firm has expertise that qualifies for the full realization of specialized services in this matter, including support for accounting, tax and financial, since preventive area up to the containment of administrative and judicial litigation.
• The office prepares weekly newsletters related to the legislation, seeking new opportunities for tax optimization, relevant decisions in administrative and judicial bodies, as well as conducts seminars for the discussion of specific tax issues, with formulation of articles in major publications, national and international.

Preventive Advisory

• Diagnostic of Tributary Opportunities with the objective to inform customers of all existing opportunities in the corporate segment which he fits, gathering tributary theses that has already filed a suit (opportunities fulfilled), and those that may be offered for the client company (new opportunities). Such opportunities are quantified previously, identifying the likely economic result in the success of demand.
• Efficient advisory services in tax structuring of the management activity, through proper interpretation and application of federal, state, and municipal tax rules.
• Consultancy related to direct, indirect and social security taxes as regards the interpretation and application of tax legislation in general.
• Tax Planning and tax structuring of transactions for the purchase and sale of companies, including diligences, reorganizations and implementation of new ventures, such as vehicle of another business, or as the final objective.
• The team develops work-oriented tax planning, drafting opinions to point alternatives of structures to be elected as an option to the conduct of business according to the Brazilian tax system.

Litigation and Administrative Tax

• Performance in the proceedings with constant monitoring of the legislation progress, the doctrine and jurisprudence.
• Issuing legal opinion on issues involving the need for pronouncement about procedures and tax collection from customers who are on the verge of introduction of administrative or judicial proceedings, or already with the litigation stage introduced.
• The performance in lawsuits involving the questioning of federal, state and municipal taxes, such as precautionary actions in general, annulment actions of tax debit, declaratory actions, repetitions of undue tax, writs of mandamus, actions of tax foreclosure and other incidental actions, in extrajudicial disputes and/or judicial, in all spheres of the judiciary branch, from the first instance up to the last, in Superior Courts, including with oral arguments at all reasonable procedural steps.
• Administration of tax liability at all levels, allowing the extinction or the reduction of amounts wrongly charged, identifying the best time for payment or installment debts, in order to protect the business company, mainly to search for its recovery and defense of their interests.

Due diligence Tax

• Identification and analysis of outgoing tax proceedings- administrative and judicial proceedings, relating to all taxes and contributions – in which the company in diligence is part of, or may be responsible in the form of tax legislation, in order to provide a thorough overview of tax contingencies.
• Evaluation of the success possibility for the audited company on the demands eventually identified.
• Analysis of fiscal procedures adopted by the audited company, face to face with the current tax legislation, to identify any procedures adopted in breach of relevant legislation and, consequently, the measurement of official notification risk.

Recovery of Tax Credit

• Preparation of the Tax Map to examine the last year-calendar (12 months) of the company’s tax assessments, check potential tax credits of IRPJ, CSLL, PIS, CONFINES, ICMS and IPI, beyond adjusting the company to the best company tax regime.
• The review of Federal Taxes aims to identify tax opportunities that were not checked by the company. The paper analyzes the calculation basis, tax rates and calculation of IRPJ, CSLL, PIS, COFINS and IPI, of the last five years of the company’s bookkeeping, according to tax legislation.
• The review of State taxes has focused on the lifting of ICMS tax credits about: