The tax burden is one of the main challenges to competitiveness in Brazil. MSN Advogados’ Tax Intelligence practice transforms this challenge into an opportunity, focusing on recovering unduly paid amounts and intelligently managing tax liabilities to generate cash flow and legal security for companies.
We specialize in Tax Credit Recovery, acting in both administrative and judicial spheres to identify, quantify, and recover overpaid taxes. Our approach utilizes advanced tax technology to conduct a thorough review of tax records, identifying hidden tax assets (such as so-called “sub-tax claims” and PIS/COFINS credits) that can be offset or refunded, injecting immediate liquidity into the business.
In the area of liability regularization, we stand out for our expertise in Tax Transactions (Law No. 13.988/2020 and PGFN regulations). We negotiate directly with the Attorney General’s Office of the National Treasury to structure agreements that allow for significant discounts on fines and interest, as well as extended payment terms, enabling the obtaining of Tax Clearance Certificates (CND) and the fiscal regularity of the company. We also act in strategic litigation, defending taxpayers against undue tax assessments and executions that threaten assets.
Detailed Scope of Services:
Tax Transaction and Installment Plans: Strategic negotiation of transaction agreements (individual or by adhesion) with the PGFN for the reduction of outstanding debt and fiscal regularization with discounts.
- Recovery of Tax Credits: Survey and administrative/judicial compensation of credits (PIS, COFINS, ICMS, IRPJ/CSLL), based on the jurisprudential theses of the STF/STJ.
- Tax Litigation: Defense in Tax Assessment Notices, Tax Enforcement Proceedings, and filing of Writs of Mandamus for the annulment of debts and release of goods.
- Consulting and Planning: Analysis of operations to optimize the tax burden, special regimes, and tax structuring of new businesses and corporate reorganizations.
- Tax Liability Management: Strategies for managing tax contingencies, aiming at protecting the assets of partners and ensuring the continuity of business activity.