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Rafael Gregorin

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Rafael Gregorin joined the Firm in 2002 and became partner in 2018. He integrates the tax practice group, with focus on litigation. Mr. Gregorin has a wide breadth of experience in tax and customs litigation, representing clients in disputes involving federal, state and municipal taxes.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

On 19 March 2024, the Public Notice of Special Settlement Agreement No. 1/2024 was published, which provides for the opening of the Zero Litigation Program 2024, a new special settlement agreement for tax debts in administrative litigation within the scope of the IRS of Brazil, the value of which, per litigation, is up to BRL 50,000,000.00. Discounts and payment terms will be determined according to the degree of recoverability of the debts. The deadline for joining the Program is 1 April 2024 to 31 July 2024.

On 3 April 2024, the Federal Revenue of Brazil (RFB) issued Normative Instruction No. 2184/2024, which regulates the tax transaction provided in Article 14 of Law 14789/2023. This transaction aims to encourage companies to pay IRPJ and CSLL (corporate income taxes), resulting from the exclusion of investment subsidies made in disagreement with Article 30 of Law No. 12973 of 13 May 2014, provided that they have not been subject to assessment.

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 30 August 2023 Bill No. 2,384/2023 was approved, 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 7 July 2023, the Substitutive Amendment to Bill No. 2,384/2023 was approved, 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.

Baker McKenzie’s VAT/Indirect Tax Practice presented “VAT Around the World Pt. 2” on 2 December 2020. This was the seventh presentation in the International VAT Conference Webinar Series, a global webinar series designed for VAT specialists from all industry sectors that aims to discuss the latest developing trends and hot topics in the VAT/goods and services tax (GST) and customs arena.