Lobo de Rizzo’s Tax practice combines deep technical expertise with an understanding of the business environment to offer legal solutions aligned with business strategy. Our practice is integrated with the firm’s other practice areas and covers both administrative and judicial litigation as well as tax advisory services across various industries, advising domestic and foreign companies on the complexities of the Brazilian tax system and constant legislative and regulatory changes.In the advisory sphere, our work focuses on tax efficiency and risk mitigation. In this context, our work encompasses tax planning, analysis of tax impacts in M&amp;A transactions, corporate reorganizations, capital market transactions, supply chain restructuring, foreign trade, and international projects. We also advise on matters related to direct and indirect taxes, transfer pricing, and social security.In administrative and judicial litigation, we act strategically in handling highly complex tax disputes at the federal, state, and municipal levels. We represent clients in administrative defenses, appeals, and judicial proceedings related to taxes such as ICMS, ICMS-ST, ISS, PIS, COFINS, IPI, IRPJ, CSLL, and social security contributions, with a focus on cases involving tax incentives and other sensitive tax issues, using a technical, sector-specific, and results-oriented approach.We closely monitor the implementation of the Tax Reform, offering support in the transition to the IBS and CBS, from the review of value chains and contracts to the operational, systemic, and regulatory adaptation of business models, with a long-term vision and a focus on business continuity.<h2>Services</h2>Tax Advisory Practice covering direct and indirect taxes, focusing on transaction structuring, regulatory interpretation, and regulatory and accounting analyses, aimed at risk mitigation, support during tax audits and in relation to tax liabilities, and decision-making support.Administrative and Judicial Litigation Strategic representation in tax disputes at the administrative and judicial levels, including the development of legal arguments, evidence, and procedural&nbsp;strategies, with a focus on reducing liabilities and preserving cash flow.Tax Audits, tax assessment notices, and ancillary obligations Preventive and reactive representation in tax audits, providing technical responses, monitoring procedures, and leading defenses and appeals against tax assessment notices.Tax diagnosis and utilization of tax credits Mapping of tax practices and identification of opportunities and risks, with documentary validation and strategies for utilizing and recovering tax credits.Corporate transactions Tax support in Corporate, Mergers and Acquisitions, and corporate reorganizations, including analysis of structures, risk allocation, and integrated collaboration with other practice areas.Foreign trade and international projects Advice on the tax implications of imports, exports, and cross-border transactions, including customs regimes, compliance, and risk mitigation.Transfer pricing (adjustment and compliance) Policy design, mapping of intra-group transactions, and definition of methods, including the preparation of documentation and support during tax audits.Tax Reform (IBS, CBS, and transition) Mapping of operations, action plan, and regulatory monitoring, including review of contracts, supply chains, and pricing models during the transition phase.<h2>Awards</h2><ul><li>Chambers Brazil</li><li>Chambers Latin America</li><li>Chambers Global</li><li>Legal 500 Latin America</li><li>Latin Lawyer 250</li><li>ITR World Tax</li></ul>

Lobo de Rizzo’s key differentiators are its personalized approach to client service and its commitment to meeting clients’ needs. I consider the firm excellent at handling complex and sophisticated matters.

Lobo de Rizzo advises companies on tax law, transfer pricing, M&A, corporate reorganizations, international trade and tax disputes.

Tax Law and Transfer Pricing | Lobo de Rizzo

Our work in the education sector is recognized for its prominent and long-standing role in consolidating the modern education sector in Brazil. Since the implementation of the major federal programs that transformed the market, we have advised the sector’s most important players at pivotal moments.With extensive experience in educational regulation, M&amp;A, and strategic transactions, we have been involved in virtually every major milestone in higher education in the country, including landmark transactions, the development of innovative legal structures, and contributions to the development of legislative and jurisprudential precedents in the sector.We have been involved in numerous mergers and acquisitions in the sector since the beginning of its consolidation cycle in 2006, including the first large-scale transaction involving distance learning (EAD), the creation of the first platforms specializing in the medical field, and the development and expansion of major higher education groups and educational systems. We have also been pioneers in thestructuring groups focused on continuing education and language courses, and have advised both strategic and financial investors in the consolidation of schools dedicated to K-12 education. Our experience encompasses large, medium, and small-scale acquisitions, always with a strong client-centered approach, as well as participation in IPO and delisting processes and the contractual and corporate structuring of a wide range of educational groups.In the regulatory front we advise educational institutions and investors on strategic engagement with the Ministry of Education (MEC) and other authorities, in administrative, litigation, and advisory contexts. We have prepared studies, risk analyses, and legal opinions that have contributed to significant advances in the sector, such as the expansion of federal funding programs and access to education and healthcare, including FIES, ProUni, and the Mais Médicos Program. In K-12 education, we also advise institutions on their interactions with the relevant state and municipal agencies.In the antitrust sphere, we were at the forefront of the first merger control cases in the education sector before CADE, helping to define the parameters that now guide transactions involving educational institutions. This work extends to administrative and judicial proceedings in regulatory and antitrust matters.Our advisory services also cover tax matters, data governance, educational agreements, and student relations, always in accordance with legal requirements and industry best practices.This track record is the result of a multidisciplinary approach that integrates the <a href="https://www.ldr.com.br/en/practice-areas/corporate-mergers-and-acquisitions/">Corporate, Mergers and Acquisitions</a>, <a href="https://www.ldr.com.br/en/practice-areas/public-law/">Public Law</a>, <a href="https://www.ldr.com.br/en/practice-areas/antitrust/">Antitrust</a>, <a href="https://www.ldr.com.br/en/practice-areas/tax/">Tax</a>, and <a href="https://www.ldr.com.br/en/practice-areas/dispute-resolution/">Dispute Resolution</a> practices, ensuring our clients legal certainty, strategic vision, and efficiency in the execution of complex projects, including transactions that require approval from government agencies and sophisticated legal structures.<h2>Services:</h2>Regulatory advisory services before the Ministry of Education (MEC)Representation in public calls for proposals, public bids, regulatory risk analysis, accreditation and reaccreditation processes, authorizations, and supervision activities, including liaison with the MEC and relevant agencies.Regulatory advisory services before state and municipal departmentsHandling regulatory proceedings related to the operation of K-12 educational institutions, supervision of educational institutions, and regulatory risk analysis.Mergers and Acquisitions and InvestmentsAdvising on M&amp;A, corporate reorganizations, and investments involving educational groups and learning platforms.Digital education and distance learningLegal support regarding distance learning standards and digital education initiatives, taking into account regulatory requirements and contractual structures.Administrative and Judicial LitigationRepresentation of educational institutions in regulatory, administrative, and judicial disputes, including disputes with regulatory agencies, consumers, and other stakeholders in the education sector.Educational and Structural AgreementsDrafting and negotiating agreements related to operations, expansion, and partnerships in the education sector.AntitrustFiling of transactions involving the education sector for approval by CADE. We have extensive experience in conducting feasibility studies for such transactions, with a focus on assessing the risk of antitrust remedies.Integration with Capital Markets and Publicly Traded CompaniesLegal counsel on transactions involving capital raising, structured investments, and publicly traded companies.Strategic Legal Consulting for Educational InstitutionsOngoing support on regulatory, corporate, and operational matters, as well as sector-specific tax consulting.

Education

Our Education practice is recognized for its prominent and long-standing role in the consolidation of the modern education sector in Brazil.

Marcelo Bez Debatin da Silveira

Experience

Graduation

Awards and Recognitions