Corporate Tax 2026

BRAZIL Law and Practice Contributed by: Júlio de Oliveira, Stephanie Makin, Gabriel Lacerda and Carlos Augusto Cruz, Machado Associados

Machado Associados With more than 35 years of experience, Machado Associados is a leading Bra - zilian law firm with a strong focus on tax law, advis - ing clients from a wide range of business sectors on strategic and complex tax matters. The firm’s tax practice is structured around three core areas: ad - visory services in direct taxes, transfer pricing and international taxation; advisory services in indirect taxes and customs duties; and tax litigation. These areas operate in a fully integrated manner, ensuring a comprehensive and co-ordinated approach to cli -

ent service. Machado Associados operates from of - fices in São Paulo (headquarters), Brasília and Rio de Janeiro. Its tax team is multidisciplinary, comprising professionals with academic backgrounds in law, ac - counting and business administration. This combi - nation of expertise is particularly valuable in highly complex matters that require a deep understanding of business, economic, operational and logistical as - pects, whether in the context of tax advisory work or litigation strategy.

Authors

Júlio de Oliveira is the leading partner of the indirect tax and tax litigation practice areas at Machado Associados, with more than 30 years’

Gabriel Lacerda is a senior associate in the tax consulting area at Machado Associados, where he has worked since 2019. Over the years while at the firm, he has assisted national and foreign clients in high-profile cases,

experience. He advises large domestic and international

companies, with a particular focus on the cosmetics industry. He regularly advises multinationals on a range of direct and indirect tax matters. Júlio is part of several committees and associations made up of companies that seek to improve the Brazilian tax system. He is a regular speaker and author of several books and articles in Brazil and abroad.

several corporate restructuring transactions and cross-border M&A transactions, as well as helping clients in defining the best strategies. He also has extensive experience in transfer pricing planning, and in studies and compliance projects with clients from different sectors. He also has experience in acting for Big Four companies.

Stephanie Makin is a partner in the tax consulting practice and a leading adviser on direct taxes, international taxation and transfer pricing. She is a key reference for complex and strategic tax matters, combining

Carlos Augusto Cruz is a partner in the tax consulting area at Machado Associados, with vast experience covering a wide range of sectors including telecommunications, mining, chemicals, retail, technology,

strong technical expertise with a pragmatic, business-oriented approach. She has extensive experience leading corporate reorganisations and cross-border M&A transactions, advising senior management on tax-efficient structures. Stephanie regularly assists clients with inbound and outbound investments, supporting foreign companies operating in Brazil and Brazilian groups expanding abroad. Her practice focuses on Brazilian CFC rules, transfer pricing and the application of Brazil’s double tax treaties, with an emphasis on structuring, risk management and dispute prevention.

logistics and agribusiness. With a background as an external and internal auditor, as well as serving as a fiscal counsellor in the trade and education sectors, Carlos Augusto has also high aptitude in accounting.

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