Pratice Areas Tax Law
Tax Benefits
We support companies in identifying, structuring, and implementing tax benefits, integrating them coherently into their investment, financing, and capitalization strategies.
Tax benefits are now a core instrument of economic policy, supporting productive investment, innovation, corporate capitalization, and specific financing operations. For companies, they represent a significant opportunity to reduce the effective tax burden, but maximizing them requires prior planning, structured decisions, and rigorous execution.
The applicable rules are highly technical, scattered across the Tax Benefits Statute (Estatuto dos Benefícios Fiscais), the Investment Tax Code (Código Fiscal do Investimento), and standalone legislation, and they undergo frequent updates. The same project can combine SIFIDE, RFAI, ICE, and other incentives, which maximizes gains but also increases the risk of unpredictability, exceeded limits, clawbacks, and corrections during audits.
The firm's intervention in tax law focuses precisely on translating the legal framework into concrete solutions for each company, aligning tax benefits with investment strategy, financing structure, and risk management, from project conception to the subsequent audit or review phase.
Services
Within the scope of the Tax Incentive System for Corporate Research and Development (SIFIDE), we support companies from the identification of R&D projects that justify an application to the interaction phase with the National Innovation Agency (ANI) and the tax authority. We help distinguish between routine activity and research, map eligible expenses, structure contracts with universities and research centers, and establish internal procedures for collecting technical and financial evidence.
We prepare the supporting documentation, monitor the submission of applications, and respond to requests for clarification and audits, ensuring coherence between accounting, project reality, and the utilization of the tax benefit. Whenever relevant, we coordinate SIFIDE with other tax incentives and non-repayable grants.
In the Investment Support Tax Regime (RFAI), we intervene from the project conception phase, helping define the investment structure in tangible and intangible fixed assets and assessing the tax impact of different location options, timelines, and asset typologies. We assist in analyzing expense eligibility, coordinating with bank financing and other tax benefits or neutrality regimes, and preparing all documentation required to access the regime.
We monitor the submission of requests and their follow-up with the competent entities, as well as the integration of the benefit into tax returns and accounting. In the event of a subsequent audit or review, we reconstruct the project's rationale and the benefit's calculation basis, preparing the technical response to the authorities.
To benefit from the Corporate Capitalization Incentive (ICE), we support the definition of the capitalization strategy best suited to each company's profile and objectives, comparing options for using equity and debt financing. We evaluate the entity's eligibility, simulate the impact of ICE on future taxation and project profitability, and formalize capital increases, ancillary contributions (prestações acessórias), and other capitalization instruments, ensuring alignment with the Commercial Companies Code and other equity-strengthening measures.
We provide support in calculating the deductible amount, preparing reports and justifying elements, accounting registration, and preparing responses to potential information requests from the tax authority. Whenever there is a combination with other tax benefits or support regimes, we analyze the applicable limits and the risk of incompatibilities, adjusting the strategy before submission.
Our approach
Strategic planning
We align tax benefits with the business and investment plan.
Support from inception
We ensure the execution of transactions, coordinating them with the incentives to be applied.
Compliance and risk management
We ensure compliance and the required documentation, mitigating the risk of audits and controversies.
FAQs
Direct reduction of the effective tax burden and greater predictability. We plan tax benefits in coordination with investment, financing, and capitalization so that they stop being isolated opportunities and become part of the company's strategy.
Whenever significant investment, innovation projects, equity reinforcement, corporate reorganizations, or new financing are at stake. At these moments, a prior analysis of tax benefits can change the form and timing of decisions.
We identify eligible R&D projects, distinguish routine expenses from research expenses, map admissible costs, and help structure contracts with universities or research centers. We prepare the application and supporting documentation, and follow up on requests for clarification or audits.
In RFAI, we provide support from project conception: asset type, location, timeline, and form of financing. We validate expense eligibility, coordinate RFAI with other tax benefits, and integrate the incentive into tax returns and accounting, also preparing the defense in case of an audit.
In many cases yes, but there are limits and accumulation rules. We analyze each project, define the sequence and weight of each benefit, and control legal caps to mitigate the risk of future clawbacks or audit corrections.
In ICE, we compare equity reinforcement alternatives, evaluate the company's eligibility, simulate the incentive's impact on future taxation, and formalize transactions (capital increases, ancillary contributions, etc.) in line with the Commercial Companies Code and tax legislation.
We design internal procedures for collecting technical and financial evidence, organize supporting dossiers, and align accounting, economic reality, and utilized benefits. In an audit or subsequent review, we reconstruct the projects' rationale and prepare the response to the authorities.
Yes. We analyze the applied benefits, verify if they were correctly calculated and framed, and identify correction risks or untapped opportunities. From there, we determine whether it makes sense to regularize, reinforce, or contest positions.
At the beginning of the project: before closing the investment, capitalization, or financing model. Once the transaction is executed, the scope for designing relevant tax benefits is always significantly reduced.