Carolina Martins Sposito joined the Firm in 2005. She integrates the tax practice group, with focus on litigation. Ms. Carolina has a wide breadth of experience in the tax collection actions filed by the tax authorities, legal theses and amnesty programs enact by the Public Administration for the payment of the debts with some benefits.
Awards and Recognitions
Carolina has been recognized by LACCA Approved editions of 2020 and 2021 as reference in tax litigation.
She graduated from Pontificia Universidade Católica (PUC-SP) with a degree in Law and from Fundação Getúlio Vargas (FGV) with a technical degree in business administration with focus on finances, she is specialized in Constitutional Tax Law from Coordenadoria Geral de Especialização da Pontifícia Universidade Católica de São Paulo (PUC-COGEAE), she took classes of accounting for non-accountants at FIPECAFE, and she is graduated in Accounting from FIPECAFI.
Portuguese and English
Trench Rossi Watanabe is awarded the CESA Gender Equality Seal
Trench Rossi Watanabe has received the CESA Gender Equity Seal in the highest category entitled “Highlight”. This award recognizes law firms that have solid Diversity, Equity and Inclusion initiatives, taking into consideration several fronts, such as internal commitment, strategic planning, communication and participation rate. With a female majority in leadership for years, this recognition reinforces […]
Transfer Pricing – Favorable Decision STJ – PRL60 (Law x Normative Ruling)
Today, the First Chamber of the Superior Court of Justice (“STJ”) concluded the trial of the Special Appeal 511.736/SP about the transfer pricing rules applicable to the resale minus method (“PRL60”) until the enactment of Law 12,715/12, more specifically about the illegality of Normative Ruling 243/02 vis a vis Law 9430/96 in place at that time. The […]
Federal Revenue Department regulates the tax settlement procedure for debts under discussion at the administrative level
In brief On August 12 2022, the Federal Revenue Department published Ordinance No. 208/2022, which regulates the tax settlement procedures set forth by Law No. 14,375/2022, that amends Law No. 13,988/2020. More details In accordance with the provisions of the Ordinance 6.757/2022, issued by the Office of General Attorney’s, the Federal Revenue Department also set forth […]
Debts relating to goodwill may be included into tax settlement agreement until July 2022
On June 30, the Federal Treasury and the Federal Revenue of Brazil enacted Legal Opinion 37/2022, to clarify some doubts of Notice 09/2022, which elected “Goodwill amortization before rules of Law No. 12,973/14” as the second tax thesis subject to a TAX SETTLEMENT AGREEMENT based on Law no. 13,988/2020 and Ordinance ME nº. 247/2020. The adhesion term […]
Amendments to the Tax Settlement Agreement Law
On June 22, 2022 it was enacted Law No 14,375/2002, preceded by Provisional Measure No 1,090/2021, which, among other legal provisions, amended Law No 13,988/2020, that instituted the possibility of settlement of federal tax and non-tax debts (similar to the Offer in Compromise institute practiced by the US IRS). The amendments to the presidential approval aim to expand […]