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Firm Name

Arrieiro Papini Advogados

Country Brazil

Practice Area
EITHER select Practice Area from this drop-down list ► Brazil - City focus - Belo Horizonte - Tax
OR If you have an earlier version of Word, type in this box: ►
Choose ONE from list of Practice Areas on last page of this document

Contact details to arrange interviews

Name Job Title Email Phone

LETS Marketing Marketing Agency rankings@letsmarketin +55 11 992763848


g.com.br

What is the Team or Department Name (as used by your firm)


Tax practice (litigation and advisory)

Head(s) of Team
Name Location

Eduardo Arrieiro Brazil – Belo Horizonte

Number of NON-PARTNERS in the


Number of PARTNERS in the team team

Non-partners who spend at least


Partners who spend at least 50% of
1 50% of their time in this 3
their time in this department team/department

Please mark anything confidential (not for publication) in red


Your practice: what sets your practice apart from other
firms?
Arrieiro Papini Advogados was founded in 2018 by the lawyers Eduardo Arrieiro and André Papini,
professionals with solid background legal careers in other law firms. We believe that solidity and
depth of knowledge in Law, combined with experience, pragmatism, creativity, ethics, personality
and understanding as to the needs and objectives of our clients are essential factors to the practice
of effective and quality law.

As our first submission to this highly regarded ranking, it’s important to introduce our main
partners. Arrieiro is a lawyer and consultant in tax matters, with a master's degree in Tax Law, who
has been working for approximately 20 years as a tax consultant for large economic groups. See
more about him in his profile on this form.

Our Firm provide legal services to Investment Funds, companies, partners, shareholders, managers,
family businesses, startups, among others in Tax Consulting, Tax Litigation, Corporate Law, Mergers
and Acquisitions (M&A), Business and Succession Planning, Corporate Governance, Contracts,
Strategic Litigation and Arbitration. Our Tax consultancy is for clients from the most diverse
business segments, such as Investment Funds, Steel Industry, Transports, Logistics, Heath Services,
Supermarkets, national and foreign company in application to federal, state, and municipal tax rules.

Our work goes from:


- Survey and appropriation of tax credits referring to direct, indirect, and social security attributes.
- Legal opinions on tax matters.
- Studies and analyses of fiscal and economic feasibility of tax incentives, transfer pricing, among
others.
- Advising individuals on tax matters related to business succession, resource repatriation programs
and the construction of fiscally efficient corporate, financial, and fiduciary structures for asset
allocation, especially investment funds.
- Advising companies on tax matters related to corporate transactions, disposal, and acquisition of
assets, including M&A and investment transactions.

In the last year, the firm advised large economic groups on tax issues involving the establishment of
receivables investment funds, real estate investment funds and exclusive funds with a combined net
worth of more than R$300 million. We also acted in the identification of tax credits over R$ 10
million for industries. In addition, we advise clients on complex tax issues, such as, for example,
transfer pricing reviews. Since its inception in mid-2018, our firm has seen significant revenue
growth, equivalent to 819% between 2018 and 2021. This is due to the fact that, although it is a
young firm, the partners are experienced and a reference in their fields.

Our practice is well-known by relevant clients to Brazilian economy and based in Minas Gerais, focus
of this research. Last year our practice had an increase of revenue. Arrieiro Papini Advogados is
already born as an important boutique firm in the legal scenario of Minas Gerais, a position that will
certainly be even more valued and consolidated from its desired nomination in Legal 500 Belo
Horizonte: Tax ranking.

Such growth is the result of assertive and effective action in highly complex matters.

Please mark anything confidential (not for publication) in red


Initiatives and innovation: what measures has your firm
introduced (or maintained) over the last year to benefit your
clients?

Where possible/relevant, please link these issues to the matters provided and/or provide tangible
examples of how these initiatives has worked in practice.

1. Tech / systems innovations – this may include the updating of the firm’s technology
capability, the introduction of AI, new policies regarding billing systems, collaboration, etc.

2. Socio-cultural initiatives – this should include diversity & inclusion initiatives (not only
women in law, but also concerning minority groups, the differently-abled, LGBQT+ etc.);
sustainability, corporate social responsibility and allied matters.

Please mark anything confidential (not for publication) in red


3. Pro-bono work (with accreditation where possible), with seniority of acting lawyer and/ or
number of hours. Please add any additional supporting information as you see fit.

Please mark anything confidential (not for publication) in red


Your practice: what do you think of our existing
rankings/commentary?
All information given here is in strictest confidence; we would encourage relevant partners to
comment on the overall ranking rather than simply their own firm / practice. Thank you.

Please mark anything confidential (not for publication) in red


IMPORTAN
T

Clients: client referees


Referee feedback is a critical part of our research. Please provide
at least 20 referees we can talk to in confidence.

You may additionally include referees from referring law firms and other organisations that
can comment on the quality of the practice. Client names are received and held by us in
strict confidence; they are not passed to any other organisation; they are not contacted for
any purpose other than The Legal 500 research. We are fully GDPR-compliant.
Please download the referee spreadsheet from submissions.legal500.com.

Please mark anything confidential (not for publication) in red


Clients: publishable clients (Client names in this section will be published)

[Please do not write client names in CAPITAL LETTERS unless strictly necessary.]

Active key clients (over the last New client Length of


12 months) (yes/no) relationship

DOX Brasil Indústria e Comércio de Aços S/A No More than 2 years

Tora Recintos Alfandegados S/A yes More than 2 years

Tora Transportes Ltda. yes More than 2 years

Tora Locações S/A yes More than 2 years

LONAX Indústria de Lonas Ltda. no More than 2 years

SADA Participações S/A no More than 2 years

LOGINVEST – Fundo de Investimento yes More than 2 years


Imobiliário

Fundo de Investimento Imobiliário STAR yes More than 2 years

SADA Transportes e Armazenagem S/A no More than 2 years

AMIS – Associação Mineira de no More than 2 years


Supermercados

sindicato nacional das empresas de No More than 2 years


medicina de grupo - sinamge

associação brasileira de planos de saúde - No More than 2 years


abramge

hospital varginha s/a – grupo serpram No More than 2 years

hospital imesa s/a – grupo serpram No More than 2 years

serpram – serviço de prestação de No More than 2 years


assistência médico-hospitalar s/a – grupo
serpram

solucionare logística jurídica ltda. No More than 2 years

Please mark anything confidential (not for publication) in red


viação fenix ltda. No More than 2 years

construtora oliveira barbosa ltda. No More than 2 years

engetec - comércio, importação e No More than 2 years


exportação de equipamentos ltda.

To add more clients, right-click in any field and select ‘Insert row below’

Clients: non-publishable clients (This list will not be published)

Active key clients (over the last New client Length of


12 months) (yes/no) relationship

DOX Brasil Indústria e Comércio de Aços S/A yes More than 2 years

Endurance Fundo de Investimento yes More than 2 years


Multimercado

Sun Capital Fundo de Investimento em yes More than 2 years


Direitos Creditórios Não Padronizados;

Tora Recintos Alfandegados S/A No 3 years

Tora Transportes. No 3 years

Tora Locações S/A No 3 years

LONAX Indústria de Lonas Ltda. No 5 years

Walter Arantes – partner at supermercado BH no More than 2 years

To add more clients, right-click in any field and select ‘Insert row below’

The Legal 500 rankings and editorial

Please mark anything confidential (not for publication) in red


METHODOLOGY

The firm and its practices

The Legal 500’s key focus remains the law firm, as reflected through each
practice area. Our rankings analyse overall team strength and capability.

Individuals

In the following pages we invite you to nominate the leading partners and senior
associates within your team. All individuals nominated on these pages may be
considered for including in our Leading Individuals, Next Generation Partners, or
Rising Stars associates tables.

While inclusion in tables for nominated individuals cannot be guaranteed, this


information is also used to help us understand notable contributions to the wider
team, which may be recognised in our editorial commentary.

With the exception of any arrivals and departures that are simply noted, all
lawyers mentioned in Legal 500 editorial are by definition recommended.

1. Leading Individuals: this category is designed to identify those that are not
only thoroughly experienced in their sector, but also demonstrate ongoing
involvement with key transactions, cases or matters, broad peer
recognition and at least ten years’ experience as a private practice partner
(or relevant industry-equivalent post).

2. Next Generation Partners: this category is designed to identify standout


younger partners with up to five years’ experience in the role.

3. Rising Stars: this category identifies key senior associates, practice


directors and counsel; in certain cases, editors may take the discretionary
step of adding counsel of seniority -generally those resulting from a lateral
hire- in one of the above categories; similarly, it may be the case that a
semi-senior is included in rising stars.

Note: evaluation of the individual listings is undertaken on an annual basis – ie:


lawyers will not automatically remain in these categories, especially if there is
little/no evidence of their activity in the work highlights included below.

Please note that partners may not automatically move from the Next Generation
Partners to Leading Individuals’ listings.

Please mark anything confidential (not for publication) in red


Your team - Partners
Please detail all partners in the team who spend over 50% of their time in the practice, along with other
partners who participate in the sector whom you wish to bring to our attention, given their contribution.

Please nominate only genuinely exceptional candidates and provide supporting evidence. Please
do not include all of your partners. We only recognise those with excellent referee and peer feedback, who
have had a prominent role in several leading matters this year (and in past years).

The Legal 500 encourages firms to put forward talented women and minority lawyers to be considered for
inclusion as leading individual/next generation/rising stars.

If you need more boxes please copy this page.

Partner 1: leading individual

Name Location Ranked in previous


edition? (Yes/no)

Eduardo Arrieiro Brazil No

Supporting information

Working for 20 years in advisory and litigation tax matters, especially in corporate reorganization
operations, mergers and acquisitions, structured funds, purchase and sale of assets,
implementation of special tax regimes and administrative and judicial tax litigation. He is a
professor in extension and postgraduate courses in Tax Law. He worked as a guest professor of the
discipline "Tax Planning - Tax Avoidance and Evasion", in the postgraduate course in Tax Law at the
Milton Campos Law School, as a guest professor of the discipline "Analysis of STF decisions that
touch the concept of income in Legal Entities ” in the postgraduate course in Tax Law at Faculdade
CEDIN and as a guest professor of the subjects “Business Activity and Contractual Organization of
the Company” and “Business Tax Planning” in the postgraduate course in Business and Tax Law at
the Varginha Law School.

Please mark anything confidential (not for publication) in red


Your team - Partners: next generation
Please provide information about junior/new/younger partners who make a material difference to the
practice. Please nominate only genuinely exceptional candidates and provide
supporting evidence.

If you need more boxes (for more next generation partners) please copy this page.

Partner: next generation 1

Name Location

Supporting information

Please mark anything confidential (not for publication) in red


Your team - Associates: rising stars
Please provide information about senior associates (and counsel) who make a material difference to the
practice, including the length of time they have been at the firm and their date of qualification.

If you need more boxes (for more associates) please copy this page.

Associate: rising star 1

Name Location

Supporting information

Your team: significant recent arrivals and departures


Please only include arrivals and departures in this practice area. Please do
include all partners, counsel and senior associates where necessary.

Name Position/ Joined/ Joined Month/


role Departed/ from/Destinati year?
Promoted? on (firm)

N/A

Please mark anything confidential (not for publication) in red


Publishable matter summary
Please pick up to three work highlights you feel reflect or best represent the capabilities of the
practice, from among those you have included in the detailed work highlights (as set out in the
following pages), and give a brief summary below.
NOTE:
a./ only provide work-highlight summaries for matters you are happy for us
to publish.
b./ we cannot guarantee that work highlights will be published if this
section is not completed.

EXAMPLE SUMMARIES

“Advised [insert company name] on acquisition of [Insert company name]”, or

“Advised consortium of banks on funding for a $6bn acquisition of a tech company”.

1. Client: Associação Mineira de Supermercados (AMIS)

Summary
AMIS is a business entity that brings approximately 90% of sales in the supermarket sector in
Minas Gerais state. AMIS members range from global supermarket giants branch’s to
supermarket micro-companies from small towns in Minas Gerais.

The office provides tax advice to the associates, through the Association, by means of
solutions to tax demands, through legal opinions, specific consultancies involving especially
federal taxes, such as Corporate Income Tax. We defend the interests of the Association and
its members against the unconstitutional collection, by the State of Minas Gerais, of the Fire
Tax.

We were successful before the Court of Appeals of the State of Minas Gerais, in the second
degree of jurisdiction. Our actions benefit hundreds of members, with values estimated in
more.

2. Client: TORA Recintos Alfandegados S/A

Summary
The company is a logistics operator that holds the concession of a Customs Industrial Logistic
Center (CLIA), located in the Metropolitan Region of Belo Horizonte/MG, on the margins of
the BR-381 highway, with easy access to the main ports and airports in the Southeast region.

It has 75 thousand m² of bonded area, including a container yard, with capacity to receive
refrigerated cargo, and rail access. It is inserted in an industrial complex structured for the

Please mark anything confidential (not for publication) in red


installation of companies, facilitating import and export logistics.

Besides being a customs and industrial warehouse, it also has a general warehouse regime. It
counts on the daily performance of consenting agencies (Federal and State Revenue Service,
MAPA and ANVISA), as well as rooms for other intervenients.

Our firm assisted the company in a legal opinion involving the payment of tax debts originally
under the responsibility of USIFAST, a company merged by TORA, in the Special Program for
Tax Regularization ("PERT"), using credits from tax losses and negative basis of calculation of
CSLL.

3. Client: DOX Brasil Indústria e Comércio de Aços S/A

Summary
DOX is one of the main industrial players in flat steel in Brazil, with estimated revenues of R$
1.7 billion in 2021. It has commercial and industrial establishments in the states of Santa
Catarina, Rio de Janeiro, São Paulo, and Minas Gerais. Besides the industrial segment, the
company inaugurated its first retail store in Contagem/MG in 2022 and is finalizing the
construction work to inaugurate other units in São Paulo/SP and Campinas/SP by the second
quarter of 2022.

Our firm assists the company in tax advisory matters, especially in issues related to obtaining
ICMS tax incentives and tax planning.

Since 2016 we had helped the company in more than R$100 million tax incentives.

Your practice - detailed work highlights


Please provide up to 20 highlight matters that represent the practice over the past 12 months.

(a) To add multiple names or jurisdictions within a matter, right-click in any field and select
‘insert row below’.

(b) To add additional matters, simply click a matter box, click the small icon in the top left
corner, then copy and paste onto a new page.

Publishable matter 1
Name of client Industry sector

Associação Mineira de Market association


Supermercados (AMIS)
Matter description

Please mark anything confidential (not for publication) in red


AMIS is a business entity that brings approximately 90% of sales in the supermarket sector in
Minas Gerais state. AMIS members range from global supermarket giants branch’s to supermarket
micro-companies from small towns in Minas Gerais.

The office provides tax advice to the associates, through the Association, by means of solutions to
tax demands, through legal opinions, specific consultancies involving especially federal taxes, such
as Corporate Income Tax. We also act in the Tax Committee, where we usually present
propositions aiming to improve the environment of the Association. The performance of the office
also involves tax advice relating to the taxation of the entity itself.

Deal value No estimate

Was it cross-border?
Jurisdiction
No

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Non Contentious

Other key team members


Name Office Practice area
Guilherme Peixoto and Ana Brazil Tax Non Contentious
Brandão

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


Ongoing

Publishable matter 2
Name of client Industry sector

Associação Mineira de Market association


Supermercados (AMIS)
Matter description

Please mark anything confidential (not for publication) in red


AMIS is a business entity that brings approximately 90% of sales in the supermarket sector in
Minas Gerais state. AMIS members range from global supermarket giants branch’s to
supermarket micro-companies from small towns in Minas Gerais.

The office provides tax advice to the associates, through the Association, by means of solutions to
tax demands, through legal opinions, specific consultancies involving especially federal taxes, such
as Corporate Income Tax. We defend the interests of the Association and its members against the
unconstitutional collection, by the State of Minas Gerais, of the Fire Tax.

We were successful before the Court of Appeals of the State of Minas Gerais, in the second
degree of jurisdiction. Our actions benefit hundreds of members, with values estimated in more
than ten million reais.

Deal value Over R$ 10.000.000,00

Was it cross-border?
Jurisdiction
No

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members


Name Office Practice area
Guilherme Peixoto and Ana Brazil Tax Litigation
Brandão

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


Ongoing

Please mark anything confidential (not for publication) in red


Publishable matter 3
Name of client Industry sector

TORA Recintos Alfandegados Logistic


S/A
Matter description

The company is a logistics operator that holds the concession of a Customs Industrial Logistic
Center (CLIA), located in the Metropolitan Region of Belo Horizonte/MG, on the margins of the
BR-381 highway, with easy access to the main ports and airports in the Southeast region.

It has 75 thousand m² of bonded area, including a container yard, with capacity to receive
refrigerated cargo, and rail access. It is inserted in an industrial complex structured for the
installation of companies, facilitating import and export logistics.

Besides being a customs and industrial warehouse, it also has a general warehouse regime. It
counts on the daily performance of consenting agencies (Federal and State Revenue Service,
MAPA and ANVISA), as well as rooms for other intervenients.

Our firm assisted the company in a legal opinion involving the payment of tax debts originally
under the responsibility of USIFAST, a company merged by TORA, in the Special Program for Tax
Regularization ("PERT"), using credits from tax losses and negative basis of calculation of CSLL.
Deal value R$ 10.000.000,00

Was it cross-border?
Jurisdiction
No

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Non Contentious

Other key team members


Name Office Practice area
n/a Brazil Tax Non Contentious

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


February 2022

Please mark anything confidential (not for publication) in red


Publishable matter 4
Name of client Industry sector

TORA Recintos Alfandegados Logistic


S/A
Matter description

[Description about TORA is in the case above.]

Besides being a customs and industrial warehouse, it also has a general warehouse regime. We
advised the company on an issue related to the ICMS tax owed to the State of Rio de Janeiro,
contesting demands concerning the payment of additional tax intended for the poverty fund and
the state fund for fiscal balance.
The discussion is extremely relevant and has a significant economic impact. It is currently under
discussion in the Court of Justice of the State of Rio de Janeiro.

We acted sponsoring the client's interests from the very beginning of the discussion.

Deal value R$ 10.000.000,00

Was it cross-border?
Jurisdiction
No

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members


Name Office Practice area
Guilherme Peixoto Brazil Tax Litigation

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


Ongoing

Please mark anything confidential (not for publication) in red


Publishable matter 5
Name of client Industry sector

Santa Clara Distribuidora Steel Company


Matter description

Since its foundation, the company has been consolidating its position as one of the largest long
steel players in the state of Minas Gerais. Over time, it has been consolidating its brand, for the
careful selection of its suppliers and for the constant development and diversification of its
product line, reaching today the point of offering intelligent solutions for the civil construction and
farming sectors.

The company has robust Distribution and Logistics Center, based in Contagem/MG, in order to
house the Group's new industrial park with a focus on providing services, especially cutting,
folding, and assembly. All this aiming at being a national reference, with world class, in
distribution of products for civil construction, agriculture and cattle-raising, and as a service
center.

Our office assists the company in issues involving the structuring of tax planning and the recovery
of PIS and COFINS tax credits, bringing significant financial results to the company.

Deal value R$ 5.000.000,00 aprox.

Was it cross-border?
Jurisdiction
no

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Non Contentious

Other key team members


Name Office Practice area
Guilherme Peixoto Brazil Tax Non Contentious

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
no

Start date End date


Current ongoing

Please mark anything confidential (not for publication) in red


Publishable matter 6
Name of client Industry sector

Aço Santa Clara Steel company


Matter description

Description about Aço Santa Clara is above. Read there.

Our office assists the company in litigious tax issues involving matters related to the fiscal war,
which, added together, reach the figure of R$ 20 million, approximately.

Deal value R$ 20 millões

Was it cross-border?
Jurisdiction
no

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members


Name Office Practice area
Guilherme Peixoto Brazil Tax Litigation

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
no

Start date End date


Ongoing

Please mark anything confidential (not for publication) in red


Publishable matter 7
Name of client Industry sector

True Color Ltda. Pigment supplier


Matter description

The company has been operating in Brazil since 2003, supplying pigments for the paint, plastics,
textile and other markets. It is installed in an industrial condominium located in Atibaia, in the
state of São Paulo, in a modern commercial center with more than 2,000 m2.
It is a German capital company and currently represents and distributes with exclusivity in Brazil
products from distributors located in Asia and Europe.

Our firm has been advising the company, in the last years, on issues involving the revision of
transfer pricing control on the import of goods, as well as on its fiscal impacts on the income tax
legislation.

This work was an important tax compliance measure and allowed the company to avoid tax risks
arising from the complexity of the legislation regarding transfer pricing controls.

Deal value No estimate

Was it cross-border?
Jurisdiction
Yes. Germany and Hong Kong

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Non Contentious

Other key team members


Name Office Practice area
n/a Brazil Tax Non Contentious

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


ongoing

Publishable matter 8

Please mark anything confidential (not for publication) in red


Name of client Industry sector

DOX Brasil Indústria e Comércio Steel company


de Aços S/A
Matter description

DOX is one of the main industrial players in flat steel in Brazil, with estimated revenues of R$ 1.7
billion in 2021. It has commercial and industrial establishments in the states of Santa Catarina, Rio
de Janeiro, São Paulo, and Minas Gerais. Besides the industrial segment, the company
inaugurated its first retail store in Contagem/MG in 2022 and is finalizing the construction work to
inaugurate other units in São Paulo/SP and Campinas/SP by the second quarter of 2022.

Our firm assists the company in tax advisory matters, especially in issues related to obtaining ICMS
tax incentives and tax planning.

Since 2016 we had helped the company in more than R$100 million tax incentives.

Deal value Over R$ 100 million

Was it cross-border?
Jurisdiction
no

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Non Contentious

Other key team members


Name Office Practice area
n/a Brazil Tax Non Contentious

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


ongoing

Publishable matter 9

Please mark anything confidential (not for publication) in red


Name of client Industry sector

DOX Brasil Indústria e Comércio Steel company


de Aços S/A
Matter description

Description about DOX is in the case above.

We advised the company on an issue related to the ICMS tax owed to the State of Rio de Janeiro,
contesting demands concerning the payment of additional tax intended for the poverty fund and
the state fund for fiscal balance. The discussion is extremely relevant and has a significant
economic impact.

It is currently under discussion in the Court of Justice of the State of Rio de Janeiro. We are
sponsoring the client's interests from the very beginning of the discussion.

Deal value R$ 50.000.000,00

Was it cross-border?
Jurisdiction
no

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members


Name Office Practice area
Guilherme Peixoto Brazil Tax Litigation

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


ongoing

Publishable matter 10

Please mark anything confidential (not for publication) in red


Name of client Industry sector

Associação Propagadora Esdeva religious


Matter description

Associação Propagadora Esdeva is the legal name of the Brazil North Province, BRN, of the
Congregation of the Divine Word, which is characterized as a religious congregation represented
and integrated by SVD priests and brothers. In Brazil, the SVD began its activities in the city of
Santa Leopoldina, Espirito Santo, on March 19, 1985, through religious, educational and assistance
works. Later, it extended its activities to several Brazilian states and established its headquarters
in Juiz de Fora, Minas Gerais, where it was constituted as a private legal entity, under the name of
"Sociedade Propagadora de Ciências e Artes".

In 1941 the association changed its name to "Sociedade Propagadora Esdeva". In 1995 the
headquarters of the Esdeva Propagating Society was transferred to the city of Belo Horizonte and
in 2004 it changed its name to "Esdeva Propagating Association".

Our office advised the Association in a lawsuit involving the collection of IPTU by the Federal
District and we obtained definitive success in the discussion, annulling the collection due to the
recognition of tax immunity.

This avoided an undue collection of more than R$ 2 million directly and at least R$ 20 million
indirectly.

Deal value R$ 22.000.000,00

Was it cross-border?
Jurisdiction
No

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members


Name Office Practice area
Guilherme Peixoto Brazil Tax Litigation

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)

Start date End date

Please mark anything confidential (not for publication) in red


March 2022

Publishable matter 11
Name of client Industry sector

LONAX Indústria de Lonas Plastic industry


Matter description

Lonax is the largest producer of plastic tarpaulins in Brazil. Founded in 2002 in the city of Sarzedo
(MG), it invests in the excellence of its products (ISO 9001 certification) and in good management
practices.
Our firm assists LONAX in tax issues involving direct and indirect taxes, especially by providing
consultancy in obtaining tax credits with significant impact on the reduction of the company's tax
burden.

We already won approx.. R$10mm in credit to this company. This is also a contentious work.

We defend the client's interests in relevant discussions involving the use of PIS/COFINS credits on
inputs used in the company's production activities. We have obtained favorable decisions in
lawsuits that assure a very relevant financial return for the company. This case is still in progress
now on the second instance.

Our assessment has been generating tax savings of approximately 100 thousand per month for
the client.
Deal value R$ 10.000.000,00 aprox.

Was it cross-border?
Jurisdiction
no

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax

Other key team members


Name Office Practice area
n/a

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Please mark anything confidential (not for publication) in red


Start date End date
Currently ongoing

Publishable matter 12
Name of client Industry sector

LOGINVEST Investment fund


Matter description

LOGINVEST FUNDO DE INVESTIMENTO IMOBILIÁRIO INDUSTRIAL is a real estate investment fund


constituted as a closed-end condominium in accordance with Law 8.668/1993 and CVM
Instruction 472/2008, as amended. Its purpose is to invest in industrial properties.

Our firm has advised the FII and its shareholders on tax issues involving questions from the
Brazilian IRS regarding income tax. In this case, we are defending the taxpayer against an
assessment notice issued by the IRS, which accuses the client of having engaged in abusive tax
planning with the purpose of not paying income tax on rents received.

However, we are demonstrating the full legality of the operations, especially the structure of the
Real Estate Fund, formed years ago and in strict legal terms.

Deal value R$ 5.000.000,00 aprox.

Was it cross-border?
Jurisdiction
no

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members


Name Office Practice area
n/a Brazil Tax Litigation

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


Ongoing

Please mark anything confidential (not for publication) in red


Publishable matter 13
Name of client Industry sector

VDF Distribuidora de Alimentos Food company


Matter description

We assist the client in lawsuits seeking the annulment of illegal confessions of tax debts with the
State of Minas Gerais, related to ICMS debts.
Our work consists in annulling the debts in instalments, due to the defects that occurred in the
confession of debts and in the instalment plan of the debts.

We have obtained favourable decisions in the first degree of jurisdiction, ruling out the
requirements and bringing great financial returns to the company.

Deal value R$ 5.000.000,00

Was it cross-border?
Jurisdiction
No

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members


Name Office Practice area
Guilherme Peixoto, Ana Brazil Tax Litigation
Brandão

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
N/A

Start date End date


Ongoing

Please mark anything confidential (not for publication) in red


Publishable matter 14
Name of client Industry sector

COOPERCON – COOPERATIVA
DE TRABALHO MÉDICO
Matter description

We assisted the client in the defense against the tax assessment notice issued by the Brazilian
Federal Revenue Service, which attributed to the Cooperative the practice of abusive tax planning,
consisting in the creation of legal entities for the provision of medical services.

More than 100 tax assessment notices were issued due to the disregard of the legal entity of the
companies. However, through our defense, we have been successful in demonstrating the legality
of the procedures adopted by the client.

We are assisting the client's interests from the very beginning of the discussion.

Deal value R$ 25.000.000,00

Was it cross-border?
Jurisdiction
No

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members


Name Office Practice area
N/A Brazil Tax Litigation

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
N/A

Start date End date


Ongoing

Please mark anything confidential (not for publication) in red


Non-publishable matter 15
Name of client Industry sector

Major supplier of biofuel


Matter summary

A task force composed of the Minas Gerais Public Prosecutor's Office, the State Revenue Service
and the Civil Police launched an operation on July 5, 2022, to combat an alleged criminal
organization focused on tax evasion and money laundering crimes in the biodiesel sector in Minas
Gerais.

According to the investigation, a group of companies used front companies in other states to
simulate sales operations of goods to Minas Gerais. The main objective of this scheme was to
generate ICMS tax credits in favor of the companies of the investigated economic group.

According to the accusations, the companies of the group failed to collect more than R$ 240
million from the coffers of Minas Gerais.

Our firm has been advising the group, with the purpose of demonstrating the illegality of the
accusations and the full regularity of the operations carried out.

Link to press coverage:


www.mpmg.mp.br/portal/menu/comunicacao/noticias/deflagrada-operacao-contra-grupo-que-
sonegou-mais-de-r-240-milhoes-de-icms-em-minas-gerais-
8A9480677FFE6C980181CE2130CB7414-00.shtml

g1.globo.com/mg/minas-gerais/noticia/2022/07/05/mp-receita-estadual-e-policia-civil-fazem-
forca-tarefa-para-combater-empresas-suspeitas-de-sonegar-mais-de-r-240-milhoes-em-
icms.ghtml

www.otempo.com.br/cidades/mpmg-mirou-quadrilha-que-provovou-prejuizo-de-r-240-mi-
sonegando-icms-em-mg-1.2694108
Deal value R$ 240 milhões

Was it cross-border?
Jurisdiction
No

Lead partner(s)
Name Office Practice area
Eduardo Arrieiro Brazil Tax Litigation

Other key team members

Please mark anything confidential (not for publication) in red


Name Office Practice area

Other firms advising on the matter and their role(s)


Firm name Role details Advising (specify the
firm/company/individual advised)
n/a

Start date End date


Ongoing

Please mark anything confidential (not for publication) in red

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