Tax and social security advisory serves as the best safeguard against unexpected costs, while also offering a valuable opportunity to streamline the tax burden, which brings a wide-ranging competitive edge to our clients.

Given the dynamic nature of the tax arena, our tax advisory lawyers work closely with clients, aiding them to foresee new costs and risks ensuing from tax regulatory developments and from shifts in the interpretation given by tax authorities and by administrative and judicial courts to tax issues.

Our tax advisory services blend data analysis technology with a focus on assisting clients in making strategic decisions. We consistently communicate in a clear, concise and straightforward manner, tailored to the business world.

The multidisciplinary expertise of our team allows us to provide tax advisory services on a number of fronts, such as:

• monitoring of the client’s routine implementation of tax regulatory changes (taxes on consumption, income and wealth);
• new business acquisition and corporate restructuring events;
• tax implications of capital market transactions and of applicable regulations;
• inbound and outbound investments, with special emphasis on the alignment of Brazilian legislation with the OECD and other international standards;
• tax planning for new local and international businesses, including by innovation and technology companies;
• identification and assessment of special tax regimes, benefits and incentives;
• tax optimization in real estate transactions;
• alternatives for companies under judicial reorganization;
• monitoring of the client’s tax compliance;
• follow-up on tax inspections and procedures;

We represent our clients’ interests in tax disputes at all administrative and judicial instances and with regard to all taxes, including social security contributions.

Our strategy revolves around three pivotal approaches: resolving conflicts; identifying opportunities; and managing liabilities.

Resolving tax-related conflicts demands readiness, assertiveness and ingenuity. Shortly after our first contact with the case, we provide our client with an analysis containing a summary of the dispute, defense strategies, and risk assessment.

Identifying opportunities is crucial when it comes to tax matters, given the intricacies of the country’s tax system and the potential impact on competitive dynamics among market players. For this reason, we work closely with clients to strategically map out the most effective solutions for optimizing their tax burden.

In addition, we streamline the management of our client’s tax liabilities by proposing effective tax savings so that they can focus on the continuity and development of their businesses. Our team specializes in conducting and negotiating tax settlements and in proposing tax liability deals – innovative solutions that can revolutionize our client’s tax liability management.

Wealth management for high-net-worth individuals (HNWIs) and family offices has become a reality in the business world, given the relevance of their investments.

Also in this realm, our work is geared towards a multidisciplinary approach spanning from taxation to contractual, corporate and succession planning issues.

We advise on the strategic handling of tax settlement transactions, a legal mechanism that allows taxpayers to negotiate tax liabilities under differentiated conditions. Our approach combines rigorous technical analysis with a negotiation-driven perspective, delivering solutions that reduce risks, optimize cash flow and provide greater predictability for businesses.

Our team specializes in:

• Structuring and negotiating tax settlement proposals at the federal, state and municipal levels.
• Assessing eligibility and classifying debts under current tax settlement programs.
• Leading negotiations with tax authorities, with a focus on swift and sustainable solutions.
• Integrating tax settlements into broader business and compliance strategies, ensuring legal certainty and economic efficiency.

Beyond regularizing liabilities, we seek to create opportunities for companies to resume growth while preserving cash flow and competitiveness.

At Lavez Coutinho, we have developed a specialized Corporate Social Security practice, focused on the strategic management of social security matters involving disability-related leaves of absence, impacts on the Accident Prevention Factor (FAP), and labor and tax risks for companies. Our goal is to turn seemingly technical issues into effective tools for cost reduction and legal certainty.

Our Corporate Social Security practice is guided by the multidisciplinary approach that characterizes our work, as well as by agility and business awareness. We seek to provide holistic and tailored legal solutions, shaped around the specific business under analysis. We combine strategic legal insight, technical and operational expertise, and active risk management, with a focus on cost prevention, tax burden reduction, and the development of customized solutions for companies across different sectors.

Main areas of practice:

• Management of Employees on Leave: monitoring and follow-up of employees on leave through the Brazilian Social Security Institute (INSS), with proactive legal advisory services aimed at mitigating social security, labor, and tax risks. We work to reduce situations of “social security limbo” and prevent improper classification of benefits as work-related accident benefits, thereby avoiding negative impacts on payroll taxation.
• Challenge of Technical Nexus (NTEP) and Benefit Monitoring: periodic monitoring of social security benefits granted to our clients’ employees. When improper work-related accident benefits are identified, we challenge the technical nexus to seek reclassification as an ordinary social security benefit.
• FAP Challenges and Appeals: detailed audit of the elements comprising the FAP when it is disclosed annually and, where discrepancies are identified, we pursue administrative measures to correct the index through tailored legal arguments. At the appellate level, we also prepare, file, and monitor strategic appeals, with a focus on overturning unfavorable decisions.
• FAP Review: thorough audit of all elements included in the company’s FAP over recent years and, in the event of inconsistencies, filing of legal claims to exclude items that were improperly considered.
• Corporate Social Security Advisory: guidance on strategic matters, particularly those involving the intersection of Social Security, Labor, and Tax Law. We assist in structuring clear and reliable legal responses, supporting companies’ decision-making in relation to employee leaves, workplace accidents and occupational diseases, FAP, RAT, and other social security impacts on payroll.

All Corporate Social Security services are designed to ensure best legal and compliance practices, optimize the tax burden arising from social security contributions, recover amounts overpaid or unduly paid, and mitigate labor, social security, and tax risks. This multidisciplinary approach aims to deliver specific and effective solutions that strengthen our clients’ financial sustainability and competitiveness.