2019

TAX

1FIRM

PROFILE

Since 1942

INDEPENDENTMULTIDISCIPLINARYFULL-SERVICE

Recognized by the Brazilian

government as

the country’s

largest exporter of legal

services.

Our client portfolio

boasts 70% of the

country’s 500 largest

companies elected by

Exame Maiores

e Melhores.

100 partners

450

4

50.000active cases

5.400clients

attorneys

offices

AREAS OF PRACTICE

Tight-knit, cohesive teams building

a multidisciplinary network

Agribusiness Banking, Finance and

Forex

Mining Oil & GasMaritime Law

EnergyConstruction Law

InfrastructureEnvironmental Law

Water and

Sanitation

Aviation

Life Sciences

Sports

Media, Internet and

Information Technology

Telecommunications

Family and

Succession

Consumer

RelationsEntertainment and

Leisure

Blockchain

Corporate

Real Estate

On-the-job Accident &

Occupational Disease

Project

Finance

Climate Change

and Sustainability

Private Equity Venture

Capital

Electoral Law

Administrative

Law and Public

Procurement

Capital Markets

Structured

Transactions

Insolvency &

Restructuring

Compliance and

Internal Investigations

Arbitration and

Mediation

M&A

Tax

Labor Luxury Law

Government

Relations

Competition

Immigration

Derivatives

Insurance and

ReinsuranceFintech

Social Security

Constitution

Criminal and Criminal

Procedure Law

Intellectual Property International Trade &

Customs

Civil and Commercial

Litigation

Chambers Latin America

Awards

Brazilian Client Firm of

the Year

2017

Chambers Latin America

Guide

Top Ranked Firm

2010 to 2020

Latin Finance Deals of the

Year Awards

Law Firm of the Year: Brazil

2009 | 2016 | 2017

IFLR Americas Awards

Firm of the Year: Brazil

2013 | 2016 | 2018

South American Firm of

the year

2018

Whos Who Legal Awards

Brazil Law Firm of the Year

2006 to 2018

Leading firm in terms of areas of practice (26), Band 1 and Individual

Lawyer recognitions (70) by Chambers Latin America 2020.

The Legal 500 Latin

America Guide

1st Tier Firm

2012 to 2018RANKINGS

AND AWARDS

Latin Lawyer 250 Guide

Recognized Firm

2009 to 2019

Latin Lawyer Elite Survey

Elite Law Firm in Latin

America

2018

IFLR 1000 Guide

Top Tier Firm

2012 to 2020

INDEPENDENT to the core and with a

MULTIDISCIPLINARY legal practice, we take a

comprehensive approach to law. We are a FULL-SERVICE

law firm.

Investing in the personal and

professional development of our

members has always been important

for the firm

OUR

TEAM

Professional

experience abroadAttorneys are encouraged to pursue

international associate programs and

postgraduate studies (LLM, etc.) abroad.

A pioneering professional

development programPinheiro Neto’s Professional Development Program

aims at improving and furthering the knowledge

and skills of attorneys since the inception of their

careers.

Expanding the

general knowledge In-house initiatives range from diversity

actions, participation of women in politics,

corporate social responsibility and general

cultural activities.

6,3

17

21,7

CORPORATE

SOCIAL

RESPONSIBILITY

Key areas

9.9

1st carbon-free law firm in Brazil

100 Thousand trees planted since

2008 = 89 Maracanã stadiums

57 thousand direct beneficiaries

170 thousand indirect beneficiaries

R$

invested millions in 2016/2017

Education

Arts and culture

Health

Sports and

entertainment

CORPORATE

SOCIAL

RESPONSIBILITY

Pro bonoWe not only encourage pro-bono work, but we

also consider it as equal stature of billable

matters. We have participated in the inception

of Instituto Pro-Bono and in the regulation of

pro bono work within the Brazilian Bar

Association (OAB).

First law firm to join the country’s

largest social investors in the

Group of Outreach Institutes,

Foundations and Companies

(GIFE)

DiversityValuing diversity is the key to building a better

workplace for all. We encourage discussions

on diversity to foster an increasingly diverse

and inclusive work environment.

Women LawyersWe support the professional trajectory and

ascension of our women lawyers, as they

pursue their career plans. Achieving

greater representativeness in discussion

forums and fostering gender equality are

among our missions.

2OUR PRACTICE

IN TAX

OUR

PRACTICE

IN TAX

The tax team of Pinheiro Neto Advogados advises both Brazilian and

foreign companies on the resolution of a variety of issues, whether in

the advisory or litigation area, judicial or administrative.

Our firm offers an in-depth vision of all relevant alternatives,

benefits and risks involved in each case toward a learned

decision of the legal and tax departments or the executives of

the companies involved.

SCOPE

AND

PRACTICE

AdvisoryCounseling, memoranda and legal opinions on a wide

range of tax matters. We adopt a forward-looking

approach while mitigating potential conflicts or disputes

with the tax authorities.

Judicial and administrative litigationAdvice in judicial and administrative proceedings

toward cancellation of infraction notices at federal,

state and municipal levels, and exemption from certain

tax charges, with active participation in claims for

refund of overpaid taxes.

Due diligence in corporate transactionsAdvice to clients wishing to invest in other companies,

identifying potential tax contingencies while offering

subsidies and specific assessments to support

the negotiations.

Tax planningExperience in planning complex structures of large

corporate groups, including cross-border tax practice,

structuring merger and acquisition agreements, product

distribution channels, among others.

Foreign tradeExpertise in tax matters involving foreign trade

transactions, among which, tax classification rules,

trade facilitation, transfer pricing, customs valuation,

and rules of origin.

Pinheiro Neto Advogados defends its clients before higher courts in judgments

with nationwide impact and in landmark cases before the Federal Supreme

Court and the Superior Court of Justice.

Our practice, which spans across all tax areas, has been awarded notable

recognitions. We have succeeded in cancelling infraction notices and hefty

penalties in a number of cases, still in the administrative sphere.

WHY

PINHEIRO

NETO?

Chambers and Partners

Latin America 2019 – Tax – Band 1

Global 2019 – Tax – Band 1

Prestigious full-service firm that commands a remarkable reputation in the

market for its dynamic tax practice. Corporate heavyweights from the banking

and energy industries benefit from its skilled advice on transfer pricing, tax

planning and social security matters. Also earns praise for its notable

capabilities undertaking administrative and judicial litigation, in addition to

advising on tax matters arising from corporate transactions.

Interviewees describe them as "an internationally recognized firm that

maintains an available team with great technical capabilities and a

multidisciplinary approach to cases.”

Another source reports: "The team is very proactive when dealing with

contentious cases," and goes on to assert: "I feel very confident in having more

than one senior practitioner working personally on my case.”

(Chambers Latin America 2019)

RANKINGS

AND AWARDS

“

The Legal 500

Latin America 2018 – Tax - Tier 1 and Tax litigation - Tier 1

Under the leadership of highly regarded department head Sérgio Farina Filho,

Pinheiro Neto Advogados has a buoyant and busy tax practice which covers

the gamut of taxation matters in Brazil. Specialisms include transfer pricing,

where partners such as Luciana Rosanova Galhardo, Flávio Veitzman and

Jorge Lopes have notable expertise; and social security, where Cristiane

Ianagui Matsumoto Gago is the name to note. On the litigation side, Luiz

Roberto Peroba Barbosa acted for Avon in a tax administrative proceeding in

which the tax authorities challenged the pricing of Avon’s intra-group domestic

transactions. Also recommended are Carlos Henrique Tranjan Bechara, whose

practice spans tax, international trade and customs; Marcelo Marques

Roncaglia, who specialises in tax litigation; Luiz Roberto Peroba; and Giancarlo

Chamma Matarazzo. In internal developments, the firm promoted Diego Caldas

Rivas de Simone to partner and Rafael Marchetti Marcondes to counsel in

January 2018.

(The Legal 500 Latin America 2018)

“RANKINGS

AND AWARDS

Latin Lawyer 250

Recognized in Tax – 2019

Pinheiro Neto […] is without doubt among the very best in Brazil. The firm has a

reputation for being able to handle the most important cases, regularly

appearing on landmark cases before the Supreme Court. For example, a major

recent case saw the team help home appliance manufacturer Whirlpool win the

right to tax credits it had accrued under a government export programme after a

25-year legal battle. Clients extol the outstanding service they receive,

commending the team’s technical skills, commitment and ethical behaviour, as

well as the use of imagination to solve difficult problems.

Work highlights: Pinheiro Neto helped US consumer credit agency Experian

keep the goodwill tax amortisation it claimed when acquiring Brazilian

counterpart Serasa in a 1 billion reais (US$266.8 million) dispute with local tax

authorities and defended software company SAP in a tax claim related to

expenses the company had deducted due to payments made to its parent

company in Germany for the licensing of software.

“RANKINGS

AND AWARDS

ITR – International Tax Review

Americas Tax Awards: America Tax Disputes Firm of the Year: Winner – 2018

Americas Tax Awards: Americas Consumer Products Tax Deal of The Year: Winner – 2017

Americas Tax Awards: Brazil Transfer Pricing Firm of The Year: Winner – 2017

Transactional Tax Survey – Tier 1 – 2019

Tax Planning Survey – Tier 1 - 2018

World Tax guide: General corporate tax - Tier 1 - 2019

World Tax guide: Tax Controversy - Tier 1 - 2019

World Tax guide: Transactional Tax - Tier 1 - 2019

RANKINGS

AND AWARDS

4OUR

TEAM

YOON CHUNG KIMCounsel, São Paulo

yckim@pn.com.br

+55 11 3247 8647

LANGUAGES Portuguese and English

EDUCATIONPontifícia Universidade Católica

of São Paulo (PUC)

Bachelor's degree – Law

INTERNATIONAL

PROFESSIONAL

EXPERIENCEInternational Bureau of Fiscal

Documentation (IBFD)

Holanda

PRACTICE

AREAS

Tax

Yoon Chung Kim is a Tax Counsel at

Pinheiro Neto Advogados, having joined

Pinheiro Neto Advogados (São Paulo) in

1994. She practices in the firm’s tax area

with focus on consulting and litigation on

direct and indirect taxes at federal, state

and municipal levels. She also has

experience in international taxation, having

worked for International Bureau of Fiscal

Documentation (IBFD). Also, she has

experience as the Head of Tax/Legal in a

multinational company (cosmetic and

personal care/hygiene sector) in Brazil.

Admitted to the Brazilian Bar Association.

www.pinheironeto.com.br

São Paulo, Brazil

R. Hungria, 1.100

01455-906

São Paulo - SP

t. +55 (11) 3247 8400

f. +55 (11) 3247 8600

Rio de Janeiro, Brazil

R. Humaitá, 275

16°andar

22261-005

Rio de Janeiro - RJ

t. +55 (21) 2506 1600

f. +55 (21) 2506 1660

Brasília, Brazil

SAFS. Quadra 2 Bloco B

Ed. Via Office. 3º andar

70070-600

Brasília - DF

t. +55 (61) 3312 9400

f. +55 (61) 3312 9444

Palo Alto, USA

228 Hamilton Avenue,

3rd floor

CA 94301 USA