Today’s businesses are under attack on all fronts as state and local taxing authorities seek to raise revenue. The resulting leakage of income reduces the efficiency of the company, its shareholders, and remaining stakeholders, such as employees and suppliers. We are experts in designing and implementing efficient international and national tax strategies encompassing the entire tax spectrum of the value chain. Considering all circumstances and relevant taxes, we identify and develop efficient tax strategies to capture long-run opportunities hidden within your individual short-term difficulties. 

Our trusted attorneys have in-depth knowledge of the ever-changing tax laws, at both national and international levels, as well as the experience and judgment to provide the highest level of advice and representation.

• Tax attributes optimization across the entire value chain, in line with the corporate purpose and strategy, and including minimization of the effective tax burden, maximization of tax deferrals and effectiveness of tax attributes;
• Holding, investment, financing, intangibles and operational efficient structures;
• Design, implementation and monitoring of value chain adjustments, including local and foreign investments, corporate restructurings (namely asset and share deals, demergers, factual and legal close of operations, re-domiciliation and relocations);
• Support to local and cross border (M&A), including funds origination and optimization, target analysis, due diligence (witch or without access to the target), análise de cash flowe modelos financeiros, negociação dos acordos, cláusulas de informação, de garantia e de indemnização, incentivos à gestão, realinhamento e reestruturação da estrutura corporativa e das operações após a conclusão, revisão das empresas participadas, desinvestimentos e transmissões;
• Transfer pricing (TP), namely avoidance of inefficiencies, complexities and controversies, together with spotting, design and implementation both locally and across jurisdictions and value chain transformation aligned the business; 
• Pragmatic and factual advice, review and monitoring of substance requirements and its alignment with the actual economic goals; 
• Intellectual property, intangibles and research and development (R&D) structure’s design, implementation and transformation; 
• Holistic tax management of financing, namely liabilities restructuration, treasury operations and cash pooling, without neglecting double taxation, VAT and stamp duties; 
• Strategic advice relating to Portuguese Speaking countries and their regional areas, including ASEAN, CEDEAO, ECOWAS, EU, Franc CFA, Mercosul, OHADA and SADC; 
• Advice on European law, double tax treaties (DTT), multilateral instrument (MLI), social security conventions, OECD TP Guidelines, base erosion and profit shifting program (BEPS) and general and specific anti-avoidance rules (GAAR and SAARs).

In nowadays constantly changing regulatory environment, taxpayers must minimize risks, improve decision-making processes and reduce costs with adequate strategies.

We safely navigate with our clients through both the local and the global tax environment and assist them in developing a holistic approach to tax risk management and litigations. 

Tax controversies are more than just one obstacle in the way – they can stop an individual, project or an entire business as they can also destroy a family’s wealth.

Receiving effective tax advice is crucial to navigate the complexities of current tax disputes and to develop robust defense strategies. Our tax controversy practice is distinguished by the sophistication and skill of our team, the depth of our experience, and our proven track record of achieving results for clients. 

• Tax disputes prevention, management and resolution; 
• Design, test and implementation of strategies and motivations; 
• Prepare, draft, file andDesign, test and implementation of strategies and motivations;  negotiate requests, rulings, unilateral, bilateral and multilateral Average Price Agreements (APAs) and other interactions with the tax authorities;  rulings, acordos prévios de preços de transferência (unilaterais, bilaterais ou multilaterais) e outras interações com autoridades tributárias;
• Assist in managing the cooperation with tax authorities, including local or joint, ongoing or special, tax audits, horizontal monitoring, corresponding adjustments, mutually agreed procedures and arbitration; 
• Negotiate and agree on controverted tax positions, including indemnity clauses; 
• Support in internal, contractual or statutory audits, seller due diligences data rooms, Internal, external or contractual controls and project management for tax benefits, incentives and subsidies. 

Managing the tax burden is an increasingly complex task that distracts professionals, entrepreneurs, corporations, and families from their core activities.

A sound tax compliance service is essential to avoid non-compliance with tax obligations and minimize costs. As a result, tax coordination requires specific high-level support and specialization.  To help you grow your business while safeguarding you from regulatory scrutiny, you need a partner with a deep understanding of the various aspects of your business and how they interface with tax law. Our advisors have the expertise and resources to help you reach your full potential. We identify and develop coordinated solutions whether you are subject to existing or potential taxes and work closely with our many state and local contacts and with legislators to resolve tax issues.  

• Insourced or outsourced tax management;
• Tax assistance retainers, outsource or insourced; 
• Regular or ad hoc reviews to tax procedures, routines and returns; 
• Audit and validation of tax matters; 
• Negations and request of tax benefits, subsidies and other incentives and its prior identification and quantification​;
• Evaluation, review and quantification of management decisions and operational, financial, investment and services activities;
• Exchange of information and horizontal monitoring; 
• Deferred tax analysis and quantification, as well as those of uncertain tax positions, namely for negotiation, accounting and statutory purposes, including Fin 48;
• Monitoring of tax attributes. 

Private clients have been the heart of our lawyers’ practices for several years. With legislation becoming more complex, the need for thoroughly managing and structuring your individual tax affairs has never been greater. Our trusted advisors listen carefully to your individual needs and circumstances to safely navigate you through the increasing tax complexities and pitfalls. Based on the broad experience of our team, we provide you with sharp domestic and international tax advice tailored to your individual priorities. 

A core element of our private clients service is to assist them to preserve and manage their wealth for both their own benefit and that of their descendants.  

Tax advice on income and wealth, including its earnings (dividends and interest) and its disposal (capital gains and other windfall gains or inheritances and gifts);

• Tax domicile, residence and conflict of jurisdictions; 
• Relocation and re-domiciliation, including tax support to expatriates; 
• Relocation and re-domiciliation, including tax support to expatriates;
• Senior staff, managers, entertainers and sportsmen and professionals in international mobility;
• Entrepreneurs, investors, founders, business angels and start up’s;
• Family business, including SFO’s and MFP’s.; 
• Nonhabitual resident tax and similar regimes; 
• Tax analysis of contributions to and benefits from pension funds and alike; 
• Tax treatment of intellectual property, including copyright, trademarks and patents, design, technical assistance and know-how;
• Foundations, trusts, unit links and other investment and philanthropic vehicles;
• Citizenship and residence permit by investment (Golden Visa and alike, in Portugal or abroad);
• Tax optimization of the acquisition and transfer of equity shares, financial investments, real estate, art and other assets;