Brazil

PwC

Av Francisco Matarazzo, 1400

Torre Milano, 15th Floor

São Paulo, SP 05001-903

Brazil

Tel: +55 11 3879 2800

Email: gileno.barreto@br.pwc.com

Website: pwc.com/taxcontroversy

Gileno Barreto is a partner at Loeser e Portela Advogados, the correspondent law firm of PricewaterhouseCoopers Legal in Brazil, and he is the leader of PwC Brazil's tax controversy and dispute resolution network.

Gileno has more than 10 years' experience in tax litigation and controversy resolution in the administrative and judicial courts related to federal, state and city taxes at all levels, and more than 20 years acting in tax consulting activities in Brazil, as well as five years in accounting audit.

He gained broad experience of the legislative procedures at the National Congress including advising on the drafting of Bills of Law, the national budget, internal commissions, budget execution and national accounting procedures among other tax policy issues and legislative activities.

During his career as a tax adviser/lawyer he has coordinated several projects related to the review of procedures adopted by national and multinational companies in compliance with Brazilian tax laws and regulations. He also has provided tax advice in structuring and restructuring projects carried out by national and multinational companies. His clients include companies in the construction, financials, insurance, chemical, forest and paper, energy and utilities, mining and oil, and education sectors. Gileno is also responsible for restructurings and M&A projects on behalf of both public and private companies.

Appointed as counselor of the Brazilian Federal Tax Administrative Council (CARF) in 2006, to its 3rd Section, Gileno served until January 2015 as vice-president of his collegiate.

Gileno is also a specialist in corporate restructuring transactions for clients in a variety of business areas; mergers and acquisitions, spin-off and mergers processes; legal due diligence processes; experience in agribusiness including tax litigation to several ethanol companies and consultancy regarding land property acquisition.

He is an adviser to several Brazilian agencies and public-owned companies; electric energy companies (Eletrobras) and to the Brazilian Energy Agency (ANEEL), the Transportation Agency (ANTT) and public-owned banks like Banco do Brasil and Caixa Economica Federal. Gileno is the project technical coordinator of the Brazilian customs modernisation plan (PMAB) rendered to the Brazilian Federal Revenue Services (RFB). He also now acts as a European Commission consultant.

Gileno graduated from the law school of UNICEUB in Brasilia-DF, and holds an MBA from the Fundação Getúlio Vargas – FGV and is post-graduating in international tax law (IBDT). He is a member of the Brazilian Bar Association, chapters of Federal District, São Paulo, Rio de Janeiro, Minas Gerais, Bahia and Sergipe.

Lautenschlager, Romeiro e Iwamizu Advogados

Av. Paulista, 1.842 - 22º andar - Torre Norte

São Paulo - SP

01310-200

Brazil

Tel: +55 11 2126 4600

Fax: +55 11 2126 4601

Email: gcm@lrilaw.com.br

Website: www.lrilaw.com.br

Gilberto de Castro Moreira Jr is a partner and the head of the tax department of Lautenschlager, Romeiro e Iwamizu. He is based in São Paulo.

Gilberto has been practising law in São Paulo since 1990. He holds a JD degree from the University of São Paulo and a PhD degree in economic and financial law from the University of São Paulo. Gilberto's practice is focused on tax law (litigation, advisory and planning).

He is an arbitrator of the EUROCHAMBERS' Mediation and Arbitration Chamber (CAE), a member of the Tax Law and Tax Litigation Committees of the São Paulo Bar Association, of the Brazilian Institute of Tax Law (IBDT), of the Scientific Council of the Tax Law Association of São Paulo (APET), of the International Association of Tax Judges (IATJ) and a sitting member of the Lawyers' Institute of São Paulo (IASP). Former councilor of the 3rd Section of the Administrative Court of Tax Appeals (CARF), former tax law professor of the Mackenzie Presbyterian University and former member of the Ethics Court of São Paulo Bar Association. He is the author of the book 'Bitributação Internacional e Elementos de Conexão' (International Double Taxation and Connection Elements); coordinator and co-author of the books 'Direito Tributário Internacional' (International Tax Law) and 'PIS e COFINS à luz da jurisprudência do CARF' (volumes 1, 2 and 3) (PIS and COFINS taxes under the CARF precedents). In total, he has co-authored 17 books and authored several articles addressing tax matters.

Lautenschlager, Romeiro e Iwamizu Advogados

Av. Paulista, 1.842 - 22º andar - Torre Norte

São Paulo - SP

01310-200

Brazil

Tel: +55 11 2126 4600

Fax: +55 11 2126 4601

Email: gcm@lrilaw.com.br

Website: www.lrilaw.com.br

Gilberto de Castro Moreira Jr is a partner and the head of the tax department of Lautenschlager, Romeiro e Iwamizu. He is based in São Paulo.

Gilberto has been practising law in São Paulo since 1990. He holds a JD degree from the University of São Paulo and a PhD degree in economic and financial law from the University of São Paulo. Gilberto's practice is focused on tax law (litigation, advisory and planning).

He is an arbitrator of the EUROCHAMBERS' Mediation and Arbitration Chamber (CAE), a member of the Tax Law and Tax Litigation Committees of the São Paulo Bar Association, of the Brazilian Institute of Tax Law (IBDT), of the Scientific Council of the Tax Law Association of São Paulo (APET), of the International Association of Tax Judges (IATJ) and a sitting member of the Lawyers' Institute of São Paulo (IASP). Former councilor of the 3rd Section of the Administrative Court of Tax Appeals (CARF), former tax law professor of the Mackenzie Presbyterian University and former member of the Ethics Court of São Paulo Bar Association. He is the author of the book 'Bitributação Internacional e Elementos de Conexão' (International Double Taxation and Connection Elements); coordinator and co-author of the books 'Direito Tributário Internacional' (International Tax Law) and 'PIS e COFINS à luz da jurisprudência do CARF' (volumes 1, 2 and 3) (PIS and COFINS taxes under the CARF precedents). In total, he has co-authored 17 books and authored several articles addressing tax matters.

Escobar Advogados

Av Paulista, 2001, 19th floor, cj 1908

São Paulo/SP – 01311-300

Brazil

Tel: + 55 11 3253 5442

Email: escobar@escobaradvogados.com.br

Website: www.escobaradvogados.com.br

His experience as a former judge of the administrative tax courts and international arbitrator, combined with a strong academic background and extensive professional experience as a lawyer and consultant of national and international companies and financial institutions are what help to set the Brazilian lawyer Marcelo Ricardo Escobar apart.

He is a former judge of the Administrative Tax Court of the State of Sao Paulo and a former member of the Tax Council of the City of Sao Paulo.

As an international arbitrator, Marcelo acts as an arbitrator and counsel in national and international procedures. Marcelo is a fellow of the Chartered Institute of Arbitrators (CIArb), and was included in the roster of arbitrators of the Hong Kong International Arbitration Centre (HKIAC) and the Arbitration and Mediation Chamber of the Federation of Industries of the State of Paraná (FIEP-CAM). He is also a member of the London Court of International Arbitration (LCIA), International Chamber of Commerce (ICC), International Council for Commercial Arbitration (ICCA), Club Español del Arbitraje (CEA); Arbitration and Public Law Commission of the Centre for Arbitration and Mediation of the Chamber of Commerce Brazil-Canada (CAM-CCBC).

In the academic area, Marcelo is taking a PhD in tax law, holds a master's degree in tax law and a specialisation in corporate law. He is also a member of the Third Sector Commission of Brazilian Bar Association – Section of Sao Paulo.

Marcelo is a visiting lecturer at the post-graduate programme of Mackenzie University, and a lecturer in several course and seminars related to arbitration, taxation and the third sector.

He is also the author of the book 'Tax incidence in the third sector: The perspective of the Brazilian Constitutional Court', and of several articles and publications dealing with taxation and international arbitration. He is fluent in English and Spanish.

PwC

Av Francisco Matarazzo, 1400

Torre Milano, 15th Floor

São Paulo, SP 05001-903

Brazil

Tel: +55 11 3879 2800

Email: fernando.loeser@br.pwc.com
fernando.loeser@lpadv.com.br

Website: pwc.com/taxcontroversy

Fernando Loeser is a partner at Loeser e Portela Advogados, the correspondent law firm of PricewaterhouseCoopers Legal in Brazil.

Fernando joined PwC in 1987, when he started working with tax consultancy and corporate law. He joined Loeser & Portela Advogados (formerly Castro, Campos & Associados – Advogados) in 1989 as senior lawyer and became a manager in 1992 before being admitted as a partner five years later, in 1997. Member of the São Paulo, Rio de Janeiro, Brasília, Bahia and Minas Gerais chapters of the Brazilian Bar Association (OAB), and also member of several chambers of commerce in Brazil. Fernando holds a bachelor's degree in law from the Law School of the Pontificia Universidade Catolica de São Paulo – PUC/SP (1991).

Fernando has more than 24 years' experience in tax litigation and controversy resolution in the administrative and judicial courts related to federal, state and city taxes at all levels as well as tax consultancy services. Fernando is also experienced in corporate law, M&A and antitrust law.

During his career he has provided legal advice in several M&A, spin-offs; due diligence and structuring and restructuring processes, as well as in the incorporation of subsidiary companies in Brazil; drafting of articles of association, corporate amendments, transfer of shares agreements and shareholder's agreement.

Fernando has also coordinated several projects related to the review of procedures adopted by national and multinational companies in compliance with Brazilian tax laws and regulations. He has also provided tax advice in structuring and restructuring projects carried out by national and multinational companies. His clients include companies in the construction, retail, mining and oil, and education sectors.

He has also been responsible for several projects related to compliance with anti-bribery and anti-money laundering laws (FCPA, Brazilian FCPA, UK Bribery Act) by Brazilian companies, conducting and/or overseeing investigation procedures as well as reporting procedures.

Fernando also provides legal counseling on public law and compliance, administrative agreements and governmental assignments, concessions and privatisations of public services.

He writes chapters and articles in various books and journals and is a native speaker in Portuguese as well as being fluent in English and Spanish.

KPMG in Brazil

Rua Arquiteto Olavo Redig de Campos, 105, 12º andar

Edifício EZ Tower – Torre A

CEP 04711-904 – São Paulo, SP

Brazil

Direct: +55 (11) 3940 8429

Email: mmatsunaga@kpmg.com.br

Website: www.kpmg.com.br

Marcos Matsunaga is a tax and legal partner and leads KPMG's tax dispute and controversy resolution services in Brazil. In addition to his national role, Marcos is also the LATAM leader within KPMG International's Global Tax Dispute Resolution & Controversy Services network. He has a wide experience in tax law and different industries sectors, with focus on advisory for prevention and resolution of tax disputes, advisory in direct taxes, due diligence, and tax planning. Marcos joined KPMG in 1997, and has been a KPMG partner since 2008.

Marcos has a bachelor's degree in law from Pontifícia Universidade Católica de São Paulo – PUC/SP and a specialisation degree in tax law from Fundação Getúlio Vargas – GVLaw. He is member of the Brazilian Bar Association, Grupo de Estudos Tributários (GET), and GETAP (Grupo de Estudos Tributários Aplicados). Marcos was named in 2012, 2013 and 2014 by International Tax Review as a tax controversy leader in Brazil and one of the most admired tax lawyers in Brazil by Análise Advocacia 500 in 2014.

PwC

Av Francisco Matarazzo, 1400 – Torre Torino

São Paulo, SP 05001-903

Brazil

Tel: +55 11 3674 2522

Email: durval.portela@br.pwc.com

Website: pwc.com/taxcontroversy

Durval A Portela is the partner-in-charge of international tax services (ITS) at PwC Brazil, with more than 25 years' experience in tax consulting, tax litigation, corporate law and corporate and tax structuring.

Durval is a regular member of the Brazilian Tax Law Institute (IBDT), the Brazilian Association of Financial Law (ABDF), the Paulista Center of Tax Studies (NUPET) and the International Fiscal Association (IFA). Durval is also active as a speaker at seminars and events on tax and corporate law.

He graduated in 1990 from the Law School of the Universidade Federal da Bahia (UFBA), he holds a master's degree in economic law from the same university and is specialised in tax law from Pontifícia Universidade Católica de São Paulo (PUC-SP).

Durval is a native speaker in Portuguese and is also fluent in English.

Rolim, Viotti & Leite Campos Advogados

Alameda Santos, nº 1940, 5º andar

Cerqueira César – São Paulo – SP

CEP: 01418-200

Brazil

Tel: +55 11 3723 7300

Email: j.d.rolim@rolimvlc.com

Website: www.rolimvlc.com/en/

João graduated in law from the University of São Paulo (USP), holds an LLM in international tax law from the London School of Economics and Political Science (LSE), a PhD in tax law from the Federal University of Minas Gerais (UFMG). He did a second PhD in international trade law, international taxation and international human rights at Queen Mary University of London. He is a tax lecturer at the Fundação Getulio Vargas (FGV) and Brazilian Institute of Tax Law (IBDT). He started his tax career at KPMG and PwC and founded in 1993 the law firm Rolim, Viotti & Leite Campos, with five offices in Brazil, one in Lisbon (Portugal) and one in Düsseldorf (Germany).

João is an international tax partner acting on tax aspects of outbound and inbound investments, international M&A, other cross-border transactions, and tax litigation. His main clients are multinational companies with operations in Brazil, and some Brazilian companies. He is director of the Iberian-American Tax Arbitration Association (AIBAT), IFA Brazilian branch (ABDF) and member of the International Bar Association (IBA) and of the British Institute of International and Comparative Law (BIICL). He has been visiting professor at the Northwestern University in Chicago (USA) and Coimbra University (Portugal), and Arbitrator for the Chamber of Commerce Brazil (CAMARB). He has published several articles on domestic and international issues and two books: 'Proportionality and fair taxation' (Kluwer Law International, 2014); 'Tax anti-avoidance rules and principles' (Normas Antielisivas Tributárias – Dialética, 2001); mostly dealing with practical cases and theoretical approaches to tax fairness in revenue collection. He has acted in some leading cases regarding state and federal taxation at the administrative tax courts, mainly in the states of Sao Paulo, Rio de Janeiro, and Minas Gerais, the Federal High Court, and the Brazilian Supreme Court. João is well known as a tax adviser and litigator, and features in rankings by The Legal 500, International Tax Review, Chambers Global, Chambers Latin America, IFLR 1000, among other legal guides.

Tauil & Chequer Advogados / Mayer Brown

Rua Teixeira de Freitas, 31 – 9º andar

20021-350 Centro

Rio de Janeiro

Brazil

Tel: +55 21 2127 4213

Email: itauil@mayerbrown.com

Website: www.mayerbrown.com

Ivan Tauil is a partner in the Rio de Janeiro office of Tauil & Chequer Advogados'´ tax law, oil & gas and real estate practices. He also has extensive experience in local and international taxation, also with taxation relating to intellectual property law. Ivan has also authored several articles and is often a lecturer in a number of legal and corporate events in Brazil, Latin America, Europe, the US and Africa. Ivan provides legal and tax advice on large oil and energy infrastructure projects and is recognised as a major leader in Brazil in such fields. Ivan graduated from PUC-RJ with an LLM in constitutional law and theory of the state. He is former president of the Scientific Council of the Brazilian Tax Law Academy, member of the International Fiscal Association and the International Bar Association, member of the editorial board of Revista Tributária e de Finanças Públicas – Ed. Revista dos Tribunais and member of the Brazilian Constitutional Law Institute.

Chambers Global 2014 and Chambers Latin America 2014 praise Ivan as "well regarded by market sources for his expert tax advice".

Tauil & Chequer Advogados / Mayer Brown

Rua Teixeira de Freitas, 31 - 9º andar

20021-350 Centro

Rio de Janeiro

Brazil

Tel: +55 21 2127 4229

Email: etelles@mayerbrown.com

Website: www.mayerbrown.com

Eduardo Maccari Telles is a partner in the Rio de Janeiro office of Tauil & Chequer Advogados. Eduardo concentrates his practice in trial, litigation and arbitration, tax and administrative law. He represents national and foreign companies as well as governmental institutions, and he assists them in all types of tax controversy as well as dispute resolution in other areas. Eduardo is specialised in oil and gas and energy tax litigation, being responsible for coordinating the firm's Brazil litigation practice.

He has as master's degree in tax law, coordinates post-graduate tax courses at Fundação Getúlio Vargas and is also a tax procedure professor in post-graduate courses. Since 2000 he has also served as a state attorney in the Attorney's Office of the State of Rio de Janeiro. His other professional assignments have included work as a tax attorney with the National Institute of Social Security (1998-2000), as external counsel for the Brazilian Institute of Municipal Administration (2000-2004) and as Treasury representative on the Taxpayer Council of the State of Rio de Janeiro (2004).