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Clarissa Giannetti Machado

Clarissa Giannetti Machado Miras joined the Firm in 1999 and became partner in 2007 . She is the Head of the tax practice group in Brazil and the Head of the Pro-Bono Committee, being a member of the Social Responsibility team of the firm. Her focus is tax consulting on corporate income and other federal taxes. Clarissa has extensive experience in the elaboration and analysis of global transfer pricing analysis and its effects vis-à- vis the local legislation. Clarissa has a wide breadth of experience in the assistance of clients for the development of efficient structures in M&A transactions, local and international restructurings, real estate and financing transactions. She also advises individuals on wealth management matters.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

On 21 September 2023, Law no. 14,689/2023 was enacted as a result of the sanction, with vetoes, by the Vice-President of the No. 2,384/2023, with the purpose of disciplining the proclamation of judgment results in the event of a tie vote within the scope of the Administrative Council of Tax Appeals (CARF), among other measures connected to tax litigation and the transaction in the collection of credits by the Federal Treasury.

On 8 August 2023, the Report of the Provisional Measure No. 1.172 of 2023, that provides new rules for the minimum wage in Brazil, was presented and approved by the Joint Committee in charge of this at the Brazilian Congress.

The Report incorporated the main changes on the taxation rules for individuals investing abroad, previously provided in Provisional Measure 1.171/23, which regulates the taxation of earnings by Brazilian individuals in financial investments, controlled entities and trusts abroad.

In brief After much anticipation, the OECD released the ‘Blueprint’ for their Pillar Two proposal on 12 October as part of its two pillar package to deal with the increasing digitalisation of the economy. The premise behind the Pillar Two proposal is simple, if a state does not exercise their…

In brief The Baker McKenzie Global Tax Team has undertaken an in-depth analysis of the ‘Blueprint’ for the Pillar One proposal to produce a digestible summary of everything you need to know. To read our summary of the Blueprint for Pillar Two please click here. Contents CHAPTER 1 – INTRODUCTION TO…