Carmagnani

Areas of practice

Direct and indirect tax consulting

• General tax consulting – advice on issues regarding federal, state and municipal taxes;

• Review of tax procedures to determine the best solution to tax obligations;

• Identification of potential tax reduction alternatives and identification of occasional tax contingencies;

• Analysis and implementation of applicable transfer pricing rules;

• Preparation and review of tax obligations, specially the Declaração de Informações Econômico-Fiscais da Pessoa Jurídica (DIPJ), Declaração de Débitos e Créditos Tributários Federais (DCTF), Demonstrativo de Apuração de Contribuições Sociais (DACON), Sistema Público de Escrituração Digital (SPED Contábil e Fiscal ), Nota Fiscal Eletrônica Mercantil (NF-e), Nota Fiscal Eletrônica de Serviços (NFS-e), Conhecimento de Transporte Eletrônico (CT-e), Escrituração das Contas Patrimoniais e de Resultado (FCONT) and Escrituração Fiscal Digital para o PIS/COFINS .

Tax litigation

The goal of our Tax Litigation team is to defend clients as taxpayers, as well as providing all applicable legal resources, offering support in the management of tax liabilities that result from any litigation. The following activities are carried out:

•  Tax Litigation in Administrative and Legal Proceedings

• Development of propositions in agreement with the taxpayer operational and commercial activities; 

• Initiation of lawsuits for non-payment of tax demands that do not comply with the constitutional legal system (illegalities or unconstitutionalities);
• Monitoring of administrative tax investigations and preparation of administrative defenses and appeals against tax assessment notices;
• Preparation of administrative tax queries and contestation of tax expert reports;
• Defense statements in Administrative Courts (CARF-MF , TIT-SP and other State and Municipal Tax Councils);

• Monitoring, for taxpayers from other States, of administrative and legal proceedings being considered in the State of São Paulo;

• Management of the tax status of taxpayers in order to obtain the Certidão Negativa e Positiva com Efeito de Negativa (CND) at federal, state and municipal levels;

• Regularization of administrative and legal pending issues in the Cadastro de Inadimplentes (CADIN);

• Assumption, by delegation of powers, of the management of the legal department processes of companies by outsourcing the whole volume of tax related proceedings.

Social security and labor

We support our clients to find solutions related to social security and labor, directly or, when required, through our partners with consolidated experience both regarding consulting and litigation aspects.