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Telirio Pinto Saraiva

Telírio Saraiva is specialist in tax consultancy and federal tax litigation, having started his career in an accounting audit company – “Big Four”. He has extensive experience with corporate restructuring projects, tax audits, legal opinions, due diligence, tax benefits review, tax planning involving legal and accounting issues, strategic administrative tax litigation and wealth management.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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 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.