Clarissa Giannetti Machado
Expertise: Transfer Pricing, Tax
+ 55 11 3048 6786
OAB SP - Nº 158764
Clarissa Giannetti Machado Miras joined the Firm in 1999 and became partner in 2007 .
She is the Head of the tax practice group in Brazil and the Head of the Pro-Bono Committee, being a member of the Social Responsibility team of the firm. Her focus is tax consulting on corporate income and other federal taxes. Clarissa has extensive experience in the elaboration and analysis of global transfer pricing analysis and its effects vis-à- vis the local legislation. Clarissa has a wide breadth of experience in the assistance of clients for the development of efficient structures in M&A transactions, local and international restructurings, real estate and financing transactions. She also advises individuals on wealth management matters.
She has worked for Ablfs McKfnzif, in the Chicago office, where she was member of the tax group focused on Latin America transactions. She also worked for Ablfs McKfnzif, in the Amsterdam office, where she was a member of the global transfer pricing group. She is registered with the New York Bar Association.
Awards and Recognitions
Clarissa has been recognized for her work in the tax field by the main legal directories.
She has been recognized as tax leader by Chambers Global and Latin America for the last 10 years.
She has been recognized as tax leader – award: “Woman in Tax” – by International Tax Review (ITR) / 2020. She was also granted by ITR the individual award “Transfer Pricing leader of the Year 2019“.
Clarissa has been recognized as Brazilian tax leader by LACCA/2020 (Latin American Corporate Counsel Association). She is frequently listed as tax leader in the corporate tax chapter from “Who’s Who Legal: Brazil“, including in the 2020 publication.
Clarissa is also habitually listed in the tax awards granted by Leaders League and Latin Laywer 250, including those related to year 2020.
She was “highly recommended – tier 1” by Legal 500 in 2019 and included in the list of “Análise Advocacia 500” in the same year.
Clarissa graduated from Universidade de São Paulo do Largo São Francisco – USP with a degree in Law and from Fundação Getúlio Vargas – FGV with a degree in business administration. She also holds a master’s degree in Law (LLM) from Columbia University School of Law – New York/EUA, where she received the award “Harlan Fiske Stone Scholar” – Columbia University.
Clarissa is the author and co-athour of different publications, such as:
– “Transfer Pricing 2021 Brazil” – Lexology GTDT (from Law Business Research).
– Chapter: “Transfer Pricing – Brazil 2020” (from IBFD Tax Research Platform).
– “Software taxes in Brazil: Begging for clarity” – 2019 (International Tax Review).
– “Brazil: Export Rules for 2008 transactions,” publicado no Tax Planning International Transfer Pricing, Vol. 10, No. 2, Fevereiro de 2009. (coautora)
– “Brazil: Transfer pricing rules applicable to export transactions carried in 2008,” publicado no Tax Planning International Indirect Taxes, Vol. 7, No. 1, Janeiro de 2009. (coautora)
– “Entraves fiscais do sistema tributário brasileiro ao investimento estrangeiro,” publicado como parte de workshop técnico organizado pelo IDB Integration and Regional Programs Department, por meio do INTAL, em junho de 2003. (coautora)
– Brazil: Restricting Tax Avoidance,” publicado no Inter-American Trade Report, Vol. 9, No. 9, Outubro de 2002 (USA). (coautora)
– “Strategic tax considerations for Brazilian Business Acquisitions”, publicado no Disclosure Transactions Magazine, Abril de 2001 (Brazil) e no Practical Latin America Tax Strategies, Julho de 2001 (USA). (coautora)
Representative matters and clients
Clarissa has been providing tax consulting services for relevant clients, such as Eaton, Siemens and Amcor/Bemis.
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 […]
Brazil: Normative Ruling regulates the option for the new transfer pricing rules in 2023
In brief On February 24th, 2022, Normative Ruling RFB No. 2,132 (“IN”) was enacted, to regulate the taxpayer’s option for the early application, in calendar year 2023, of the new transfer pricing rules (“TP”) and royalty deductions provided for in Provisional Measure No. 1,152/2022 (“MP”). The IN reaffirmed the irrevocable nature of the option and […]
News and deadlines for submitting Foreign Assets statement for Brazilian Central Bank and Individual Income Tax Return 2023
In brief Brazilian taxpayers can already submit their Declaration of Foreign Assets to Brazilian Central Bank (the so called “DCBE”), which is due on April 5, 2023 (until 6pm). The late filing of the declaration, as well the filing error or failure to deliver the declaration, may give rise to application of penalties to the declarant […]
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 […]
Published Normative Instruction n. 2095/ 2022 regarding the deadline to file Rural Real Estate Tax Return
On 07/26/2022, the Normative Instruction No. 2095 of 2022 (“IN 2095/22″) was published, which establishes the deadline from August 15 to September 30, 2022 to file the for delivery of the Rural Real Estate Tax Return ( so called ” DITR”) for individuals or legal entities required to submit it, as well as the main […]