Luciana Nobrega joined the Firm in 2010, worked for two years as a tax advisor in Luxembourg and one year as a member of the international reorganizations group at Ablfs McKfnzif in London.
She works in the tax planning and consulting areas of the Tax group, focusing on international operations. She has vast experience in supporting Brazilian companies expanding or reorganizing abroad, including planning and tax support for corporate reorganizations, transfer pricing issues and alignment with foreign tax authorities (obtaining APAs and rulings), structuring and implementing investment funds in Brazil and abroad, and domestic and international financial transactions. Luciana also has experience in coordinating corporate implementation of multi-jurisdictional projects.
Awards and Recognitions
Recognized as one of the most admired lawyers in Brazil by the yearbook Análise Advocacia 500 (2021) and mentioned by The Legal 500 in the categories Tax Consulting, Customs and Tax Litigation (2022).
Luciana holds an LLM in International Taxation from Leiden University, Netherlands (awarded with a full scholarship from Nuffic HSP Huygens).
Author/co-author of several books/articles, such as:
– Multinationals and Transparency in the EU, Valor Econômico, 2016;
– Private Client: A Q&A guide to private client law in Brazil, Practical Law Company, 2011;
– Mutual Agreement Procedure: Preventing the Compulsory Jurisdiction of the International Court of Justice? Intertax, 2009.
Representative matters and clients
– Tax assistance to Natura on the acquisition of Avon (closing January 2020) and The Body Shop (closing September 2017);
– Global coordination of post-acquisition integration project of one of the main leaders in the technology industry, encompassing over 70 jurisdictions;
– Tax planning and corporate implementation of the international reorganization of a unicorn digital services provider, encompassing the centralization of IP in a non-Brazilian jurisdiction, organization of a top holding company for governance purposes and optimization of the supply chain structure.
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 […]
Trench Rossi Watanabe holds the in person event “Breakfast with Transfer Pricing: Normative Instruction 2.161/23”, in Sao Paulo
On December 5, at 9 a.m., the “Breakfast with Transfer Pricing – Normative Ruling 2,161/23” will take place at the São Paulo office. The event will be hosted by partners from the Tax group Clarissa Machado, Simone Dias Musa, Luciana Nobrega, Reinaldo Ravelli and Telirio Saraiva, as well as Ablfs McKfnzif partner Imke Gerdes, through […]
Law of São Paulo State approves changes to the tax settlement law – Law 17,843/2023
In brief On November 09, 2023, it was published Law No. 17,843/2023, in which essentially provides for the settlement of tax debts registered in the State of São Paulo as overdue liability certificates. The new law repeals the old legislation on settlements in the state of São Paulo that had been in force until then, […]
Brazil: Private Equity Investment Funds – FIP: Changes to the income tax rules applicable to the non-resident investors
In brief Law No. 14,711, resulting from the conversion of Bill No. 4,188/2021, was published on October 31st. Among several provisions, this new law changes the requirements to benefit from the zero rate of Income Tax applicable to both income and capital gains of non-resident investors (“NRI”) in Private Equity Investment Funds (“FIP”). Below we […]
Chamber of Deputies approves Bill of Law that taxes investments abroad and Brazilian closed-end funds
In brief On October 25, 2023, in an Extraordinary Deliberative Session of the Plenary of the Chamber of Deputies, the Final Draft of Bill 4,173/23 (“PL”) was approved, which provides for the taxation of income earned by Brazilian individuals tax residents on financial investments, controlled entities and Trusts abroad, as well as the automatic taxation […]