Marcelle Silbiger De Stefano
Expertise: International Trade, Tax
+ 55 11 5091 5921
OAB SP - Nº 357338
Marcelle joined the Firm as a law clerk in 2013 and as an associate in 2015. She integrates the Tax group, with focus on indirect and direct tax consulting and trade and commerce matter. Marcelle has experience in taxation of several sectors (media, technology, consumer goods, pharmaceutical, chemical, among others), both involving local and international transactions. Marcelle also has extensive knowledge of customs valuation, tariff classification, customs special regimes, import and export controls, as well as foreign trade agreements.
She has worked in Ablfs & McKfnzif office in Zurich in the Tax and Wealth Management group.
She graduated from Pontifícia Universidade Católica de São Paulo with a degree in law. She holds aN LL.M. degree in Tax Law from Insper, with extension in Master of Law and Economics from the University of St. Gallen, Switzerland, with full scholarship from the Lemann Foundation.
Activities outside the office
Marcelle is a member of the Customs Committee of the Brazilian Bar Association (2019-2021 term).
Author/co-author of several articles, such as:
– Brazilian Chapter – Doing Business in Brazil – SWISSCAM
– Importações indiretas: solução ou problema – Estadão
– Carta branca à multa aduaneira – Valor Econômico
– Ministério da Economia altera condições para concessão de ex-tarifários – Estadão
– A reformed Mercosur? Don’t hold your breath – Latin Lawyer
– Dual-use Export Controls in International Transit and Transhipment – Capítulo sobre Brasil – WorldECR
– Autuações em importações por encomenda: mais um desafio aos contribuintes – JOTA
– Questões polêmicas sobre apuração de haveres na dissolução parcial de sociedade limitada – Análise segundo a Jurimetria – Revista dos Tribunais
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 […]
Brazilian Federal Revenue issues a new Ruling on Customs Valuation
In June 23, 2022, the Brazilian Federal Revenue published the Normative Ruling 2,090/22, which provides for the declaration and inspection of the customs value of imported goods. The Normative Ruling 2,090/22 provides for relevant changes in comparison to previous rulings, amongst which we highlight the following: Prohibition of the application of transaction value when the […]
The Federal Government publishes a Decree that excludes the THC from the customs value
On 06/07/2022, the Federal Government issued Decree No. 11,090, which excludes from the customs value the terminal handling costs (“TCH”). The Decree No. 11,090 amends Article 77 of the Customs Regulation (Decree No. 6,759/2009), which lists the amounts that should be included in the customs value. The customs value is the Import Duty basis. For […]
Brazilian Federal Revenue modifies the import and export customs clearance procedure
On 03/18/2022, the Brazilian Federal Revenue issued Normative Instruction No. 2,072/2022, which brought relevant changes on the import and export customs clearance. The Brazilian Federal Revenue can now require several documents from the importer when there are doubts about the price charged in the import operation, in cases where the goods are parameterized for the […]
Conclusion of the ratification process of the Convention for the Avoidance of Double Taxation between Brazil and Switzerland
On June 9, 2021 the Brazilian Government issued Decree No. 10,714/2, which concludes the ratification process of the Convention for the Avoidance of Double Taxation entered between Brazil and Switzerland (“Tax Treaty”). We highlight below the main aspects of the Tax Treaty (others aspects may be relevant depending on the case): Income Maximum Rate – […]