The tax burden in Brazil is high - but your company's effective burden may be lower. With consistent tax planning, credit recovery and a strategy for the new tax system, your company stops paying more than it owes.
A tax regime unsuited to the company's profile can lead to paying more tax than necessary.
Tax Reform (Constitutional Amendment 132/2023). The new system is being phased in gradually. Companies without prior planning lose competitive advantage and margins.
PIS, COFINS, ICMS and IPI tax credits are often underused due to flaws in calculation processes.
Unmanaged tax litigation erodes cash. A strategic defense reduces liabilities and creates opportunities for installment plans and debt extinguishment.
The transition to the new system - with IBS, CBS and the Selective Tax replacing PIS, COFINS, IPI, ICMS and ISS - begins in 2026 and is completed in 2033. Companies that act early will gain cost and operational advantages.
Assess the impact on my company →We map how the tax replacement affects your effective burden, prices, margins and long-term contracts.
While both systems coexist (2026–2032), there are planning windows that can significantly reduce the burden.
Existing contracts may need rebalancing clauses. We identify the risks before they materialize.
Guidance on differentiated regimes, tax cashback and the new automatic collection model through Split Payment.
We work to reduce the effective burden and protect the company from tax risks, in line with the business strategy.
Pilli & Fanucchi's tax practice works on three complementary fronts: proactive planning to lawfully reduce the tax burden, recovery of underused credits and strategic defense in administrative and judicial litigation.
Our edge lies in integrating the three. A company that only litigates misses planning opportunities. One that only plans without risk control accumulates liabilities. We work in a coordinated way, connecting each tax decision to its financial and operational impact on the business.
The tax team is led by partner Tamiris Freire de Oliveira, a specialist in tax and customs law, with broad experience in administrative litigation before CARF (the federal Administrative Tax Appeals Board) and in planning for mid-sized and large companies in Campinas and São Paulo State.
Every tax decision is analyzed in light of its impact on cash, margins and competitiveness - not just formal compliance.
We identify unnecessary ancillary obligations, redundancies in calculation processes and simplification opportunities with no tax risk.
Well-conducted tax litigation reduces liabilities, suspends enforceability and creates room to negotiate with the Federal Revenue Service and tax attorneys' offices.
Complete tax counsel - from planning to court, including credit recovery and Tax Reform readiness.
Analysis of the most suitable tax regime (Actual Profit, Presumed Profit or Simples Nacional), structuring of transactions for tax efficiency and review of federal, state and municipal tax calculation processes.
Impact analysis of EC 132/2023 and LC 214/2025 for the client's industry and business model, identifying opportunities in the transition period and reviewing contracts and pricing.
Identification and use of underused PIS, COFINS, ICMS, IPI and IRPJ/CSLL credits. Administrative and judicial refund and offset requests, with statute-of-limitations and risk analysis.
Defense against infraction notices, challenges and appeals before the Federal Revenue Service, State Finance Departments (SEFAZ) and CARF. Litigation strategy aimed at extinguishing or reducing the tax claim, with risk and provision analysis.
Writs of mandamus, annulment and declaratory actions, tax foreclosures and debtor's defenses. Defense against collections by the federal, state and municipal governments, with arguments aligned with Superior Court of Justice (STJ) and Supreme Court (STF) case law.
Structuring of differentiated ICMS regimes, accreditation with the State Finance Department, use of regional and industry incentives, and analysis of tax benefits applicable to the industry.
Counsel on the tax aspects of M&A, corporate reorganizations, mergers, spin-offs and family holding companies. Structuring tax-efficient transactions compliant with the Federal Revenue Service.
Preventive tax audit to identify hidden liabilities, unused credits and regulatory risks before they turn into assessments or administrative disputes.
In a conversation with our tax team, we map the main points of attention in your operation and identify opportunities to reduce the burden and recover credits.
Response within 24 business hours
Partner in charge of Pilli & Fanucchi's tax practice, Tamiris Freire de Oliveira focuses on strategic tax planning, tax credit recovery and administrative and judicial tax litigation for companies in Campinas and the region.
With experience in federal, state and municipal taxes, she coordinates companies' readiness for the Tax Reform (EC 132/2023 and LC 214/2025) and leads the most complex matters before the Federal Revenue Service, CARF and the Judiciary. She also works in customs law, advising companies with import and export operations.
We work with companies in Campinas and São Paulo State that need to reduce their tax burden, recover credits and protect themselves in litigation - with legal certainty and a focus on results.
Content produced by our team on the tax reform and tax topics that directly affect your company's results (in Portuguese).
Talk to our tax team and find out.
Planning, credit recovery and Tax Reform strategy - all tied to your business results.
Briefly tell us about your company and your main tax question - planning, credits, litigation or the reform.
We reply within 24 business hours to better understand the context and schedule a conversation with the specialist.
At the end of the conversation, you'll have a map of the main points of attention and the most relevant opportunities.