Reinaldo Ravelli Neto
Expertise: Succession planning, Tax
+ 55 11 3048 6808
OAB SP - Nº 222625
Reinaldo Ravelli Neto joined the Firm in 2005 and became partner in 2016. He integrates the tax practice group, with focus on tax planning and transactions. Mr. Ravelli has a wide breadth of experience in tax advisory for Foreign Investments, Mergers & Acquisitions (M&A), Corporate Reorganizations, Financial Transactions, Investment Funds, Real Estate Transactions and Project Financing.
He worked in Ablfs McKfnzif at the Amsterdam office in the International Tax practice group.
Awards and Recognitions
Ravelli has been recognized by several legal directories such as Latin Lawyer 250, Legal 500, International Tax Review and Lex Latin for the transactions he advised and coordinated.
He graduated from Universidade de São Paulo with a degree in Law and from Fundação Getúlio Vargas in Business Administration. He is a tax specialist from Fundação Getúlio Vargas, he holds a master in Law (LL.M.) from Northwestern University School of Law, and a certificate in Business Administration from Kellogg School of Management.
Activities outside the office
Mr. Ravelli acts as a speaker in seminars and panels promoted by professional organizations, chambers of commerce and universities.
Author/co-author of several books/articles, such as:
– A não incidência de PIS e Cofins sobre ganho por compra vantajosa reconhecido no contexto de uma combinação de negócios. In: Impactos tributários decorrentes da adoção do IFRS no Brasil – Uma década de debates. São Paulo, Blucher, 2019;
– Custos diretos e indiretos das garantias: seus impactos na realidade empresarial. In: Garantias Judiciais no Processo Tributário – Cenários, Perspectivas e Desafios. São Paulo, Blucher, 2018;
– Alocação da propriedade intelectual e a tributação dos royalties no Projeto BEPS: o combate aos planejamentos tributários “abusivos” e o “nexus approach”. In: Tributação da Economia Digital. São Paulo, Saraiva, 2018;
– A tributação dos lucros auferidos por sociedades controladas e coligadas no exterior e o regime tributário de transição – RTT. In: Controvérsias Jurídico-Contábeis (Aproximações e Distanciamentos). 4º Volume, São Paulo, Dialética, 2013.
Representative matters and clients
– Advised Natura Cosmeticos S.A. (“Natura”) on structuring, coordinating and reviewing the main tax aspects for the acquisition of Avon Inc. (“Avon”) in a US$ 2 billion transaction;
– Advised Natura on the acquisition of The Body Shop (“TBS”), in an transaction of more than US$ 1 billion;
– Advised The Boeing Company (“Boeing”) on the structuring and review of the main tax aspects of what would be the joint venture with Embraer S.A. (“Embraer”), in a transaction valued at US$ 4.75 billion;
– Advised Whirlpool (“Whirlpool”) on the coordination and review of the main tax aspects of the carve-out and global sale of the compressor business to Nidec (“Nidec”), in a US$ 1.08 billion transaction;
– Advised Yara International ASA (“Yara”) on the main tax aspects related to the acquisition of the remaining stake in Galvani Indústria, Comércio e Serviços S.A. (“GICS”) in a deal estimated at US$ 165 million;
– Advised Walmart Inc. (“Walmart”) on the sale of 80% of its operations in Brazil to Advent Inc. (“Advent”).
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 […]
Provisional Measure eliminates income tax of non residents’ financial investments
In brief On September 22, 2022 the Brazilian Federal Government published Provisional Measure (“MP”) No. 1,137 reducing to zero the rate of the Withholding Income Tax (“WHT”) levied over income earned on several financial investments by non-residents investors. The MP will be submitted to the National Congress for analysis and voting. If converted into law, will […]
Brazil: Federal Decree changes the Financial Transactions Tax Regulations (Decree 6306/2007)
Last Friday, 07/29/2022, Decree No. 11,153/2022 was published, promoting changes in Decree No. 6,306/2007, the Financial Transactions Tax Regulations (“RIOF”). Items VII to IX in article 15-B of the RIOF, which establish a 6.38% tax rate in exchange transactions related to credit card operations, were altered. The new wording of the items no longer refers […]
Brazil: The Senate begins their analysis of the Income Tax Reform under the ordinary rite
In brief The Brazilian Federal Senate received for consideration the Bill of Law of the Income Tax Reform (PL 2337/2021) approved by the Chamber of Deputies on 09/02/2021. The Brazilian Federal Senate received for analysis and voting the Bill of Law of the Income Tax Reform (PL 2337/2021) approved by the Chamber of Deputies on […]