Tax strategy to reduce risk and protect results.
We handle judicial and administrative tax litigation, defending companies and taxpayers in tax matters. We also assess tax liabilities and advise on measures to reduce risk, contingencies, and potential losses.
We believe tax intelligence represents an important competitive advantage. That’s why we combine firm client defense with careful, preventive analysis of their operations.
How do you identify tax liabilities before an audit?
Identifying tax liabilities in advance involves a careful review of the company’s operations, its tax assessment and payment procedures, and its compliance with current tax law. This work includes reviewing ancillary obligations, verifying tax classifications, analyzing tax credits, and assessing differing interpretations between the taxpayer and the tax authorities. The goal is to anticipate contingencies and adopt corrective or defensive measures before a notice of infraction is issued, turning fiscal risk into a manageable decision rather than a surprise.
The logic of a preventive audit is damage control. If an assessment error is identified, the company can opt for installment payment or correction, avoiding penalties and the blocking of tax-clearance certificates (CND), which are essential for continued operations and participation in public tenders. It’s proactive management that keeps a tax liability from becoming unpayable due to the charges tied to overdue tax debt.
Do you work at the administrative level, the judicial level, or both?
We work at both levels. In administrative litigation, we represent clients before federal, state, and municipal tax authorities, defending against notices of infraction, filing administrative appeals, and handling consultation proceedings. In judicial litigation, we appear before the courts in actions challenging the enforceability of taxes, the constitutionality or legality of tax rules, and the recovery of amounts wrongly collected. The choice between the two routes depends on the specific case and is always guided by a cost-benefit analysis and likelihood of success.
The rationale behind our dual approach is to offer the client every possible layer of protection. In many cases, formal errors by the tax authorities can be corrected quickly at the administrative level. When the dispute involves complex legal theories or constitutionality issues, the judicial route is the way to secure the taxpayer’s rights and seek recovery of amounts unduly paid.
Do you advise on tax planning?
Yes. Tax intelligence represents a competitive advantage, so our work isn’t limited to defending against litigation. We advise companies on evaluating tax structures, analyzing alternative tax classifications, and identifying lawful tax-optimization opportunities. We always work within the bounds of the law, focusing on efficiency and compliance, helping the client make informed decisions about the tax impact of their operations. Proper tax planning reduces risk, protects margins, and contributes to the business’s financial sustainability.
The logic applied here is sustainable efficiency. We don’t look for “shortcuts” — we apply tax benefits, special regimes, and favorable interpretations of the law correctly. Good tax planning improves cash flow and lets the company reinvest its resources into its own growth, while remaining fully compliant with its obligations to the government.