2.0 Tax
Tax advisory for operations that outgrew their complexity
Review, compliance and structure to operate safely within one of the world's most complex tax systems, from day-to-day tax matters to international operations.
Languages: Portuguese and English · Focus: compliance and review · Last updated: July 2026
Tax advisory is the service that reviews a company’s operations, controls and tax obligations to ensure compliance and identify risks and credits. At PFM, the scope includes tax and corporate review, transfer pricing, expatriate compliance, assessment of tax debts and credits, and advisory on infraction notices, for Brazilian companies and foreign subsidiaries.
Scope
What's included in PFM's tax advisory?
PFM’s tax advisory covers three fronts: review and compliance, international operations, including transfer pricing and expatriates, and structure and administrative litigation, with assessment of tax debts and credits, advisory on infraction notices, and support for corporate restructurings.
2.1
Review and compliance
- Analysis of operations and tax controls
- Tax and corporate review
- Review of accessory obligations
- Income tax return review
- Analysis of tax and corporate bookkeeping
2.2
International operations
- Transfer pricing analysis and planning
- Compliance for international expatriate transfers
- Advisory on structuring foreign investments
- Customs matters and special regimes
2.3
Structure and litigation
- Assessment of tax debts and credits
- Advisory on infraction notices
- Corporate restructuring (M&A)
- Tax due diligence
- R&D tax incentives
Who it's for
Who is PFM's tax advisory for?
The service serves two profiles: subsidiaries of foreign companies, facing transfer pricing, expatriates and HQ compliance requirements, and mid-sized Brazilian companies that grew and accumulated tax complexity, and now need a review, not improvisation.
Subsidiaries of foreign companies
Brazilian operations with intercompany transactions, expatriate executives, and an HQ that requires documented compliance.
- Transfer pricing under Brazil's new rules
- Expatriate tax compliance
- Foreign investment structuring
- Technical communication in English with HQ
Mid-sized Brazilian companies
Businesses that grew and accumulated tax complexity, and now need review, not improvisation.
- Risk review before it becomes an assessment
- Unclaimed tax credits
- Tax preparation for M&A or investors
- Adapting to the tax reform
Comparison
What's the difference between reactive tax management and PFM's approach?
In reactive tax management, the company only acts once an assessment or notice arrives, and pays for it. In PFM’s approach, review is periodic and structured: risks are mapped ahead of time, credits are identified as part of normal operations, and corporate decisions are already resolved on the tax dimension.
| Criteria | Reactive tax management | PFM's tax advisory |
|---|---|---|
| When action happens | After an assessment or notice | Periodic review, before the risk materializes |
| Tax credits | Found by chance, often expired | Active assessment of debts and credits |
| International operations | Handled case by case, undocumented | Transfer pricing and expatriates documented |
| Restructurings and M&A | Tax dimension assessed too late | Due diligence and corporate design from the start |
| Relationship with tax authorities | Improvised defense in infraction notices | Structured technical advisory in administrative litigation |
Method
How does PFM's tax advisory work?
The work follows four steps: tax diagnosis of the operation, a risk-and-opportunity map prioritized by relevance, an action plan with owners and deadlines, and ongoing follow-up, because Brazilian tax law keeps changing, and compliance is a routine, not a one-off project.
01
Tax diagnosis
Review of operations, tax controls and obligations, in Portuguese or English, with access to systems and latest filings.
02
Risk and opportunity map
Risks quantified and prioritized, credits identified, and improvement points in corporate structure and processes.
03
Action plan
Recommendations with owners, deadlines and estimated impact, from a routine adjustment to a full corporate restructuring.
04
Ongoing follow-up
Monitoring legislative changes, including the tax reform, and periodic compliance reviews.
Frequently asked questions
Common questions about tax advisory
A tax advisory firm reviews a company’s operations, controls and tax obligations to ensure compliance, identify risks before they become assessments, and locate unclaimed tax credits. It also supports structural decisions, corporate restructurings, foreign investments and international operations, with the tax dimension resolved from the design stage.
We don’t work with promises of tax savings. PFM’s commitment is compliance and efficiency within the law: reviewing risks, recovering legitimate credits, and structuring operations correctly. When a path isn’t safe or isn’t our specialty, we say so, integrity is an operating value at the firm, not a slogan.
Transfer pricing rules define how transactions between related companies in different countries must be priced for tax purposes. Any Brazilian subsidiary that buys, sells, or contracts services from its HQ or affiliates abroad needs to document these transactions, and Brazil’s rules were significantly overhauled to align with the OECD.
Yes. The transition to the new consumption-tax model requires reviewing pricing, contracts, systems and credits over several years of coexistence between the two regimes. PFM maps the impact on the business and organizes the adaptation plan in stages.
Yes. We handle compliance for international executive transfers, obligations in Brazil, coordination with the home country, and documentation of the tax position, a recurring topic among subsidiaries of foreign groups.
In many cases, yes. The debt-and-credit assessment identifies amounts paid incorrectly or unclaimed within the legal deadline. PFM quantifies, documents and pursues recovery through the appropriate administrative channels, without aggressive positions.
Related services
Natural complements to this service
1.0
Accounting BPO
The day-to-day tax and accounting execution at the same standard as the advisory.
4.0
Risk Management
Internal controls and compliance to sustain tax compliance over time.
Risks mapped before they become an assessment
Schedule a tax diagnostic conversation. In one meeting, we understand your operation and point out where the risks, and the credits, are.