The globalization process experienced in recent decades has led to the expansion of the activities of companies and individuals to other jurisdictions, also exposing them to risks related to inefficient or even questionable investment structures by the tax authorities involved.

In this context, Rücker & Longo Advogados has a highly qualified and experienced team in international and national tax consultancy, acting especially advising groups of foreign companies and individuals with activities in Brazil, as well as issues involving Brazilian investments abroad.

Our partners and collaborators advise on our clients’ day-to-day tax issues, as well as on interpreting international tax agreements, planning and optimizing the tax cost of international operations and investment structures, on importation and exportation tax structures related to goods and services.

On the other hand, we have extensive expertise in matters involving holdings, real estate investment funds and equity interests, transfer pricing, as well as the restructuring of individual and family with high net worth.

The international network of Rücker & Longo Advogados contributes to excellence advice on matters involving international taxation.

Among other issues, the team at Rücker & Longo Advogados is at the disposal of our clients to advise on the following matters:

     (i) taxation of corporations and individuals in cross border activities;

     (ii) international and national tax planning;

     (iii) interpretation of international taxation agreements;

     (iv) rules and preparation of transfer pricing files;

     (v) foreign tax credits;

     (vi) application of the Controlled Foreign Corporation – CFC and thincap rules;

     (vii) taxation on the importation of products, services, royalties, know-how and management fees;

     (viii) export pre-finance, FIP and FII holding structures (corporate or personal);

     (ix) implementation of family holdings and restructuring of assets;

     (x) financial modeling of international investments; and

     (xi) other matters related to international activities.