Carolina Cantarelle Ferraro

Carolina Ferraro acts in tax administrative and judicial litigation, with regular representation before Brazilian courts. She represent Clients in several situations, whether counseling during tax audits, pursuing administrative appeals of audit results at administrative courts, or litigating tax matters at the lower and superior courts.

• Represented the largest oil services company in the world in several tax litigations of more than BRL 300MM, including an administrative federal proceeding charging the payment of taxes due upon importation of goods suspended by Drawback regime and two lawsuits regarding the compliance with REPETRO´s requirements for purposes of cancellation of ICMS charge.
• Represented a leading Drilling Contractor in several tax litigations, in the approximate amount of BRL 700MM, including administrative federal proceedings issued by the Brazilian Internal Revenue Service (“IRS”) due to the understanding that the contractual split between charter and services agreement was artificial.
• Represented Client that operates in the Exploration and Production (E&P) in several tax litigations, including judicial measures to eliminate WHT on imported services payments, in view of the tax exemption established by DTT executed between Brazil and France, and administrative federal tax assessments of more than BRL 200MM issued by the Brazilian IRS charging IRPJ and CSLL due to the challenge of deductibility of expenses and calculation basis of financial revenues, that was canceled by the unanimous 2nd level administrative decision.
• Represented Client that is the market leader in the distribution of fuels and lubricants in Brazil, at lower and superior courts, in a Tax Foreclosure filed by State of Amapá aiming the charge of ICMS (State VAT) due to diesel sales, worth more than BRL 500 MM, which was afterwards canceled by Amapá due to the tax debt waiver.
• Represented satellite operator in several administrative and judicial tax litigations, in the approximated historical amount of BRL 300MM, including the filing of a judicial measure in order to cancel several tax assessments filed by the State of Rio de Janeiro aiming the charge of ICMS (State VAT) due to satellite capacity leasing. The first level decision determined the cancelation of the assessments.
• Represented a big life sciences company in the administrative defenses and appeals against Tax Assessments issued by the State of Espírito Santo, charging ICMS (State VAT) and fine over transactions performed by the company, disregarding tax benefits. This case is considered strategic because it involves import and interstate operations with medicines applied to Covid-19 treatment.
• Represented an agribusiness company that mainly exports wooden furniture, in tax assessments involving social security contributions in the total approximated amount of BRL 90MM. Carolina has prepared defenses and appeals, with regular representation before administrative and judicial courts and she has also advised the Client in tax consulting, contract matters and assisted in the procedures of tax settlement and adhesion to tax installments programs handled by Federal Government.
• Assisted a Drilling Contractor in the administrative proceeding of applying for REPETRO-Sped in relation to the importation of the drilling rig, under the modality of temporary admission for economic use, with exemption from the payment of federal taxes.
• Assisted Clietns with tax matters related to the contractual split between charter and services agreements, not only regarding tax litigation at administrative and judicial levels, but also in relation to tax consultancy and contractual analysis;
• Assisted Clients with tax audits, in answering tax inspection notifications, in dealing with tax authorities and in formulating overall audit strategies.
• Assisted Clients in the procedures of tax settlements and also in adhesion to tax installments programs handled by federal, state and municipal spheres.

• Universidade do Estado do Rio de Janeiro – UERJ, Master, Public Finance, Taxation and Development
• Fundação Getúlio Vargas (FGV/RJ), LLM, Tax Law
• Universidade do Estado do Rio de Janeiro, Bachelor of Law (JD equivalent)

• Brazil

• Portuguese
• English
• Spanish