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Partner of the Demarest's Tax Litigation area, Marcelo Salles Annunziata has a Bachelor's Degree in Law by the Law School of the University of São Paulo (USP) and is a specialist in the Tax area, especially in the litigation sphere. He has a Master’s Degree in Tax Law by USP and is the author of several academic studies published in the best magazines in the country. He also teaches Tax Law in preparatory courses for public examinations and has lectured frequently on the most important subjects of Tax Law. Author of several articles in prestigious newspapers, Annunziata is the source of the main press vehicles of Brazil, which seek their opinion on Tax issues. He has been nominated for many years as the "leading lawyer in his field" by Chambers, Leaders League, Latin Lawyer 250, International Tax Review, and more recently by the Legal 500, Who's Who Legal and Analysis 500 directories.

Experience

- Advised several companies in recent years in large Tax litigation cases in the largest disputes of this kind in the country, in theses such as the exclusion of ICMS in the calculation basis of PIS and COFINS (in companies such as GOODYEAR, RECKITT, AMCOR PACKAGING, GIVAUDAN, MAGNA , PROCOMP, etc.)

- Advised the company ROCKWELL to discuss the thesis of COFINS - 1% increase in imports;

- Advised the company VISTEON SISTEMAS AUTOMOTIVOS in discussion about credit of IPI for compensation with other federal taxes

- Advised the company CHEVRON ORONITE in great legal dispute for the cancellation of a PIS debt

- Advised the company TELEFÔNICA in consulting related to the adhesion to a special installment payment program of the Federal Government

Academic Qualifications

- Master in Tax Law by the University of São Paulo (USP), São Paulo, Brazil (2002)

- Specialization in Civil Procedural Law by the Pontifical Catholic University of São Paulo (PUC-SP), São Paulo, Brazil (1998)

- Bachelor of Laws by the University of São Paulo (USP), São Paulo, Brazil (1994)

Associations

- Member of the Institute of Tax Research (IPT)

- Member of the Institute of Fiscal Policy (IPF)

Languages

Portuguese, English and Spanish

Partner in Demarest’s Tax area, Marcelo Salles Annunziata holds a Master’s degree in Tax Law from USP and a specialization in Civil Procedural Law from PUC-SP. He is the author of several academic studies published in some of the most highly regarded journals in the country including some of the most important media vehicles. Marcelo is a professor of Tax Law in preparatory courses for public examinations and has lectured frequently on the most important topics in the area. With a practice focused mainly on judicial litigation, he has been cited for many years as a “leading lawyer in his field” by Chambers, Leaders League, Latin Lawyer 250, International Tax Review, and more recently by Legal 500, Who’s Who Legal and Análise Advocacia 500.

Advised Chevron Oronite in a major legal dispute for the cancellation of a PIS debt.

 Advised Telefônica in relation to the adhesion to a special installment payment program of the Federal Government.

Advised Tullet in obtaining an injunction that was able to prevent the application of Normative Instruction No. 1.862/18 of the Federal Revenue Office regarding the imputation of liability to the partners and managers of legal entities.

Advised HDI in tax audits and in the defense of four tax notices, currently amounting to approximately BRL 270 million.

Assistance to clients regarding the offsetting of credit for a judicial decision that recognized the right to exclude ICMS from the PIS and COFINS tax basis; and filing a judicial measure in order to ensure that such credit is taxed by IRPJ and CSLL only at the time of approval of the offsetting declarations.

Master’s degree in Tax Law from the University of São Paulo (USP), São Paulo, Brazil (2002)

 Specialization in Civil Procedural Law from the Pontifical Catholic University of São Paulo (PUC-SP), São Paulo, Brazil (1998)

 Bachelor of Laws from the University of São Paulo (USP), São Paulo, Brazil (1994)

Author of the article “Agenda Tributária de 2019” [“Tax Agenda of 2019”], O Estado de São Paulo, March 2019.

 Author of the article “Agravo em Recurso Especial e a nova jurisprudência defensiva do STJ” [“Injunction in Special Appeal and the new case law of the STJ”], Portal JOTA, March 2019.

Author of the article “Fiança e Seguro Garantia: abrangência atual, aspectos em comum e diferenças” [“Surety Bond and Insurance Bond: current scope, common aspects and differences”], in Garantias Judiciais no Processo Tributário [Judicial Guarantees in Tax Proceedings], Editora Blucher, 2018.

Author of the article “Custo Ilegal nas Importações” [“Illegal Costs on Imports”], O Estado de São Paulo, March 2018.

Author of the article “Execução Fiscal” [“Fiscal Execution”], portal JOTA, December 2017.

Author of the article “Substituição do Depósito em Dinheiro por Seguro Garantia” [“Replacement of the Cash Deposit with Insurance Bond”], portal JOTA, May 2017.

 Author of the article “Multa isolada em compensação tributária – ilegitimidade dos lançamentos prematuros efetuados pela Receita Federal do Brasil” [“Isolated fines in tax offset – illegality of the premature assessments made by the Federal Revenue Office”], Migalhas, March 2017.

Author of the article “Novo CPC: decisões polêmicas contra a Fazenda Pública” [“New CPC: controversial decisions against the Public Treasury”], portal JOTA, March 2017.

Author of the article “Reflexos da compensação de estimativas de IR e CSLL na apuração de saldo negativo” [“Impacts of the offsetting of IR and CSLL estimates in the determination of negative balance”], O Estado de S. Paulo, February 2017.

Author of the article “Denúncia espontânea na compensação tributária” [“Voluntary disclosure in tax offsetting”], Valor Econômico, September 2016.

Member of the Institute of Tax Research (IPT)

 Member of the Institute of Fiscal Policy (IPF)

Portuguese, English and Spanish

Partner of the Demarest's Tax Litigation area, Marcelo Salles Annunziata has a Bachelor's Degree in Law by the Law School of the University of São Paulo (USP) and is a specialist in the Tax area, especially in the litigation sphere. He has a Master’s Degree in Tax Law by USP and is the author of several academic studies published in the best magazines in the country. He also teaches Tax Law in preparatory courses for public examinations and has lectured frequently on the most important subjects of Tax Law. Author of several articles in prestigious newspapers, Annunziata is the source of the main press vehicles of Brazil, which seek their opinion on Tax issues. He has been nominated for many years as the "leading lawyer in his field" by Chambers, Leaders League, Latin Lawyer 250, International Tax Review, and more recently by the Legal 500, Who's Who Legal and Analysis 500 directories.

Experience

- Advised several companies in recent years in large Tax litigation cases in the largest disputes of this kind in the country, in theses such as the exclusion of ICMS in the calculation basis of PIS and COFINS (in companies such as GOODYEAR, RECKITT, AMCOR PACKAGING, GIVAUDAN, MAGNA , PROCOMP, etc.)

- Advised the company ROCKWELL to discuss the thesis of COFINS - 1% increase in imports;

- Advised the company VISTEON SISTEMAS AUTOMOTIVOS in discussion about credit of IPI for compensation with other federal taxes

- Advised the company CHEVRON ORONITE in great legal dispute for the cancellation of a PIS debt

- Advised the company TELEFÔNICA in consulting related to the adhesion to a special installment payment program of the Federal Government

Academic Qualifications

- Master in Tax Law by the University of São Paulo (USP), São Paulo, Brazil (2002)

- Specialization in Civil Procedural Law by the Pontifical Catholic University of São Paulo (PUC-SP), São Paulo, Brazil (1998)

- Bachelor of Laws by the University of São Paulo (USP), São Paulo, Brazil (1994)

Associations

- Member of the Institute of Tax Research (IPT)

- Member of the Institute of Fiscal Policy (IPF)

Languages

Portuguese, English and Spanish

Partner in Demarest’s Tax area, Marcelo Salles Annunziata holds a Master’s degree in Tax Law from USP and a specialization in Civil Procedural Law from PUC-SP. He is the author of several academic studies published in some of the most highly regarded journals in the country including some of the most important media vehicles. Marcelo is a professor of Tax Law in preparatory courses for public examinations and has lectured frequently on the most important topics in the area. With a practice focused mainly on judicial litigation, he has been cited for many years as a “leading lawyer in his field” by Chambers, Leaders League, Latin Lawyer 250, International Tax Review, and more recently by Legal 500, Who’s Who Legal and Análise Advocacia 500.

Advised Chevron Oronite in a major legal dispute for the cancellation of a PIS debt.

 Advised Telefônica in relation to the adhesion to a special installment payment program of the Federal Government.

Advised Tullet in obtaining an injunction that was able to prevent the application of Normative Instruction No. 1.862/18 of the Federal Revenue Office regarding the imputation of liability to the partners and managers of legal entities.

Advised HDI in tax audits and in the defense of four tax notices, currently amounting to approximately BRL 270 million.

Assistance to clients regarding the offsetting of credit for a judicial decision that recognized the right to exclude ICMS from the PIS and COFINS tax basis; and filing a judicial measure in order to ensure that such credit is taxed by IRPJ and CSLL only at the time of approval of the offsetting declarations.

Master’s degree in Tax Law from the University of São Paulo (USP), São Paulo, Brazil (2002)

 Specialization in Civil Procedural Law from the Pontifical Catholic University of São Paulo (PUC-SP), São Paulo, Brazil (1998)

 Bachelor of Laws from the University of São Paulo (USP), São Paulo, Brazil (1994)

Author of the article “Agenda Tributária de 2019” [“Tax Agenda of 2019”], O Estado de São Paulo, March 2019.

 Author of the article “Agravo em Recurso Especial e a nova jurisprudência defensiva do STJ” [“Injunction in Special Appeal and the new case law of the STJ”], Portal JOTA, March 2019.

Author of the article “Fiança e Seguro Garantia: abrangência atual, aspectos em comum e diferenças” [“Surety Bond and Insurance Bond: current scope, common aspects and differences”], in Garantias Judiciais no Processo Tributário [Judicial Guarantees in Tax Proceedings], Editora Blucher, 2018.

Author of the article “Custo Ilegal nas Importações” [“Illegal Costs on Imports”], O Estado de São Paulo, March 2018.

Author of the article “Execução Fiscal” [“Fiscal Execution”], portal JOTA, December 2017.

Author of the article “Substituição do Depósito em Dinheiro por Seguro Garantia” [“Replacement of the Cash Deposit with Insurance Bond”], portal JOTA, May 2017.

 Author of the article “Multa isolada em compensação tributária – ilegitimidade dos lançamentos prematuros efetuados pela Receita Federal do Brasil” [“Isolated fines in tax offset – illegality of the premature assessments made by the Federal Revenue Office”], Migalhas, March 2017.

Author of the article “Novo CPC: decisões polêmicas contra a Fazenda Pública” [“New CPC: controversial decisions against the Public Treasury”], portal JOTA, March 2017.

Author of the article “Reflexos da compensação de estimativas de IR e CSLL na apuração de saldo negativo” [“Impacts of the offsetting of IR and CSLL estimates in the determination of negative balance”], O Estado de S. Paulo, February 2017.

Author of the article “Denúncia espontânea na compensação tributária” [“Voluntary disclosure in tax offsetting”], Valor Econômico, September 2016.

Member of the Institute of Tax Research (IPT)

 Member of the Institute of Fiscal Policy (IPF)

Portuguese, English and Spanish