Brazil - Taxation of cross-border mergers and acquisitions

Despite internal economic challenges and slower global economic growth than forecast, Brazil remains attractive for foreign investors because of a variety of economic factors, including its relative economic and political stability, control over inflation, and large and growing consumer market.

Like other Latin American countries, Brazil has made significant strides in amending its legislation to attract direct foreign investments.

Brazil’s current government has a sweeping privatization program. Also, aiming at boosting investor and business confidence, Brazil is taking the necessary steps to become a full member of the Organisation for Economic Co-operation and Development (OECD).

The Brazilian mergers and acquisitions (M&A) environment is dynamic. Tax laws are subject to frequent changes, creating not only pitfalls that can frustrate M&A tax advisors but also tax planning opportunities. Further, although Brazilian tax law often seems inflexible, it offers significant flexibility for Brazilian tax planning.

Good acquisition due diligence is important everywhere, and particularly in Brazil. The complexity of the tax system, and the high amount of tax litigation necessary to resolve tax issues, among other issues, can complicate the evaluation of Brazilian targets and negotiations significantly.

Overall, there is a relatively high tax burden in Brazil, with complex and interrelated tax provisions. Good tax planning is therefore essential for the parties involved in any M&A project in Brazil so as to attain a high level of tax compliance as well as to capture adequate and viable tax upsides.

OECD BEPS Action Plan

As the recipient of significant foreign direct investment, Brazil has been concerned about BEPS for many years. The country has had a number of international tax rules and other measures in place for several years to stem the flow of earnings outside the country (e.g. thin capitalization rules, higher withholding tax (WHT) rates for remittances to tax haven jurisdictions, limitation on the deductibility of royalties payments, and CFC rules).

Despite this, as a G20 country, Brazil has been engaged in the OECD’s work and the Brazilian Revenue Service has already expressed its intention to adopt BEPS recommendations. Nevertheless, Brazil has a long history of going its own way where international tax standards are concerned, and it’s possible that Brazil will pick and choose to adopt only those aspects of the proposals that suit Brazil’s domestic purposes.

Some of the BEPS-related legislative developments in Brazil are the following:

• Action 5 Harmful tax practices: (i) Brazilian Revenue Service Normative Ruling (NR) 1,658/2016 set forth the concept of substantial activities requirement for determining the preferential tax regimes for Brazilian tax purposes.
• Action 12 Mandatory Disclosure Rules: the government has tried to introduce a mandatory disclosure regime, which was rejected by the Congress.
• Action 13 Country-by-Country Reporting: the mandatory annual filing of country-by-country (CbyC) reports was introduced in Brazil on December 2016 through Brazilian Revenue Service Normative Ruling (NR) 1,681/16.
• Action 14 Mutual Agreement Procedure: Normative Ruling (NR) 1,669/2016 regulated the mutual agreement procedure for the resolution of tax-related disputes between Brazil and its network of treaty partners.

2015 amendments

A number of changes in the Brazilian tax legislation were put in place as of 2015, directly or indirectly affecting both M&A and cross-border transactions. The main changes that occurred in this period are discussed below.

Premium tax amortization

Historically, almost all M&A deals in Brazil involved a share transaction with goodwill attributed to future profitability of the target.

Aggressive tax planning and its impact on tax collections created significant pressure from the tax authorities to revoke the tax goodwill benefit, especially with respect to intragroup acquisitions. Although not revoked, tax authorities increased rigor in tax audits in order to limit the utilization of goodwill on non-straightforward operations.

Brazilian tax legislation determines that at the time of acquisition of shares, the excess payment must be broken down between equity value and premium (e.g. premium = price — book value).

The premium must be allocated based on the International Financial Reporting Standards (IFRS) standards, supported by Purchase Price Allocation (PPA) to be prepared after the acquisition. The premium paid over the acquired company’s net equity must first be allocated to fair value of assets/liabilities and intangibles and the remaining portion price allocated as goodwill (based on future profitability).

If any piece of the premium paid ends up being allocated to fair value of assets (tangible or intangible), it is likely that the tax amortization/deduction will be possible upon the merger of acquirer and the acquired company:

• Fair value of tangible assets: in accordance with Brazilian legislation, the portion disclosed as fair value will either be subject to (i) depreciation, in the event of a step-up, or (ii) taxation, in case of a step-down.
• Fair value of intangibles: the amortization of intangible assets that have a defined useful life should be deductible for tax purposes.
• Goodwill: the remaining portion of the premium allocated as goodwill (based on future profitability) is amortizable over a minimum 5-year period (maximum limit of 1/60 per month/20 percent per year).

The PPA (prepared by an independent expert to support the fair value of the assets/liabilities) must be filed with the Brazilian Revenue Service or with the Register of Deeds and Documents within 13 months after the closing date.

In transactions involving the acquisition of an investment in a Brazilian legal entity by foreign investors via a local investment vehicle, Brazilian tax authorities might argue that such vehicle has been interposed solely for the purposes of obtaining the premium/goodwill tax amortization and that the premium tax amortization should be disallowed.

Adequate planning is therefore essential to ensure the acquisition structure is consistent with best practices and the prevailing case law on this matter.

Payment of dividends and interest on net equity

Dividend payments are based on net accounting income (after taxes). Alternatively, companies can pay dividends out of retained earnings and profit reserves.

Dividends paid out of retained earnings and certain reserves are not subject to withholding income tax if related to profits generated after January 1996.

Note that dividends are neither treated as expenses nor as deductible amounts, regardless of the type of shares they relate to (voting or preferred).

According to Brazilian law, in addition to dividends, Brazilian subsidiaries may also pay interest on equity to their shareholders.

From a Brazilian tax perspective, interest on equity is deductible for Brazilian tax purposes while it is considered as remuneration for the investor based on shareholders’ net equity.

In general terms, interest on equity is calculated by applying the daily pro rata variation of the government’s long-term interest rate (TJLP) on the adjusted net equity of the Brazilian entity, considering all equity variations occurred during the year.

The interest on equity deduction is limited to the highest of 50 percent of the payer’s retained earnings and 50 percent of the payer’s current profits, with some adjustments.

Interest on equity is subject to 15 percent WHT on the date it is paid or credited to the recipient. This rate increases to 25 percent if the recipient is located in a low-tax jurisdiction.

On the other hand, the local payer is allowed to deduct interest on equity paid or credited to resident or non-resident shareholders for corporate income tax and social contribution tax on profits purposes.

Furthermore, when the shareholder is a resident entity the withholding tax can generally be credited, although other tax consequences may arise.

Therefore, as there may be significant tax opportunities in paying interest on equity, consideration shall be given to the tax treatment in the foreign jurisdiction of the beneficiary (e.g. whether the income is taxable, whether Brazilian withholding tax is creditable).

Purchase of assets

Brazil’s successor liability rules are broad and also apply to asset deals. Brazilian legislation stipulates that private corporations that acquire goodwill or commercial, industrial, or professional establishments from an unrelated entity and continue to operate the target business are liable for historical taxes related to the intangibles or establishments acquired.

However, where a seller ceases to operate its business, the buyer becomes liable for all the business’s historical tax liabilities.

The seller of assets is subject to income tax and social contribution tax (totaling approximately 34 percent) on any increase in value of the assets. For Brazilian tax purposes, no preferential rates apply to capital gains; both operational and non-operational gains are taxed at the same rate, although there is a difference in the tax treatment of capital and ordinary losses.

Purchase price

For tax purposes, it is necessary to apportion the total consideration among the assets acquired. It is generally advisable for the purchase agreement to specify the allocation, which is normally acceptable for tax purposes provided it is commercially justifiable.

Goodwill

Goodwill is recorded as a permanent asset and cannot be amortized for tax purposes, even though it may be amortized for accounting purposes.

Depreciation

The acquisition cost of fixed assets is subject to future depreciation as a deductible expense according to their economic useful life.

Tax attributes

Value Added Tax (VAT) credits may be transferred where an establishment is acquired as a going concern. Tax losses and other tax attributes remain with the seller.

Value Added Tax

Programa de Integração Social (PIS) and Contribuição para Financiamento da Seguridade Social (COFINS) may apply, depending on the type of asset sold. These taxes apply on the sale of most assets other than property, plant and equipment (e.g. fixed assets).

Imposto sobre Circulação de Mercadorias e Prestação de Serviços de Transporte Interestadual e Intermunicipal e de Comunicação (ICMS) applies to the transfer of inventory. The tax paid may become a credit to the buyer insofar as these same products are later sold or used as raw materials in the manufacture of products sold by the buyer. The ICMS credits generated on the purchase of the assets generally can be used to offset the ICMS debts arising from later taxable transactions, such as sales. There are restrictions on a taxpayer’s ability to use credits on the purchase of fixed assets. Generally, the sale of fixed assets is not subject to ICMS, but ICMS credits generated on the purchase of fixed assets may have to be written off.

Excise tax

Imposto sobre Produtos Industrializados (IPI) also applies to the transfer of the inventory, where the inventory was directly imported or manufactured by the seller. IPI tax paid may also be creditable by the buyer where the product is to be used in the manufacture of other products. IPI may also apply on the sale of fixed assets, where the asset was directly imported or manufactured by the seller and the subsequent sale occurred within 5 years of the date the asset was recorded as a permanent asset by the seller.

Transfer taxes

Municipal real estate transfer tax (ITBI) may apply to the transfer of real estate.

Stamp duties do not apply.

Tax on financial operations

Loans granted to the Brazilian company are also subject to Financial Transactions Tax. The rate may vary from 0.38 to 6 percent, depending on the characteristics of the debt (mainly related to the maturity date).

Purchase of shares

The sale or purchase of shares in a Brazilian entity is more common than an asset deal because of lower documentation requirements and indirect taxation.

The taxation of a share sale depends, to some extent, on the residence of the seller and buyer.

A Brazilian corporate seller (pessoa jurídica) is subject to income tax and social contribution tax on the net gain from the sale of shares. In most cases, where a seller owns a significant interest (usually more than 10 percent), the gain is calculated as the difference between the gross proceeds and the proportional book value of the target entity’s equity.

Whether the seller is a Brazilian individual or a non-resident, the gain is subject to progressive WHT rates (15 percent to 22.5 percent) depending on the quantum of the capital gain.

For a Brazilian individual, the gain is calculated based on the difference between the gross proceeds and the capital contributed or paid in a previous acquisition.

For a non-resident, because of the lack of clarity of the relevant tax provisions, there is some debate about how the capital gain is determined.

A possible interpretation is that the gain is normally calculated as the difference between the amount of foreign capital registered with the Brazilian Central Bank and the gross sales proceeds in the foreign currency. Another possible interpretation is that the gain should be calculated as the difference in Brazilian currency between the sales proceeds and the capital invested, thereby including exchange fluctuations in the tax base. The tax authorities published a normative instruction stating that the gain should be calculated in Brazilian currency. The different positions arise because of differences between the wording of the law and the regulations. It is important to state in the sales contract whether the sale price is gross or net of WHT.

As of 2004, Law 10.833/03 introduced the taxation of non-residents’ capital gains with respect to the assets located in Brazil even when neither party to the agreement is a Brazilian resident. Capital gains on the sale of publicly traded shares are exempt for non-residents, provided certain formalities are met and the seller is not a resident of a tax haven.

According to the Brazilian legislation, equity investment funds (FIP) are not legal entities but condominiums with shares held by their investors. Generally, FIPs are exempt from corporate taxes (income and social contribution taxes on profits) and gross revenue taxes (PIS, COFINS), since some requirements are met. Non-resident investors are not subject to Brazilian taxation on the redemption of FIPs’ quotas, even where the redemption follows liquidation.

The exemption only applies where certain requirements are met. Among other things, the non-resident must:

• hold less than 40 percent of the FIP’s quotas
• not be entitled to more than 40 percent of the income paid by the FIP
• not be resident in a low-tax jurisdiction
• not hold the investment in the FIP through an account incorporated in accordance with BACEN rules.

One significant advantage of a share sale over an asset sale is that, where a share sale is structured properly, the amount paid in excess of the net equity of the target may generate an amortizable premium or a step-up in the tax bases of otherwise depreciable or amortizable assets.

This opportunity is not available where shares in a Brazilian company are purchased directly by a non-resident and is not available to the same extent where assets are purchased.

To take advantage of this opportunity, the acquisition of shares needs to be made through a Brazilian acquisition vehicle.

The liquidation or merger of the acquisition vehicle and the target allows the premium paid on the shares to become recoverable in certain situations. To the extent that the premium relates to the value of recoverable fixed assets or the value associated with the future profitability of the company, the premium could be amortized or otherwise recovered through depreciation.

As mentioned earlier, the goodwill allocation must follow IFRS: it must be allocated first to the fair value of assets/liabilities and intangibles and the remaining portion is allocated as goodwill (based on future profitability).

Tax indemnities and warranties

Generally, tax legislation and prevailing jurisprudence stress that corporate entities resulting from transformations, upstream or downstream mergers, and spin-offs are liable for taxes payable by the original corporate entity up to the date of the transaction. This liability is also applicable on the wind-up of companies whose business continues to be exploited by any remaining partner, under the same or another corporate name, or a proprietorship.

Successor liability depends on one of two factors:

• the acquisition of the business (also referred to in the case law as the acquisition of goodwill, meaning business intangibles)
• the acquisition of the commercial, industrial or professional establishment (i.e. elements that are inherent in and essential for the business).

This rule treats an acquisition of assets that constitutes a business unit similarly to the acquisition of shares of a company where the seller goes out of business. If the seller stays in business with another activity, then the buyer’s responsibility is secondary, meaning that the tax authorities must first target the existing seller’s assets to satisfy the existing tax contingency.

Regardless of whether the transaction is structured as an asset or share acquisition, due diligence is extremely important in Brazil. The buyer should seek proper indemnities and warranties.

Tax losses

In general, tax losses are kept by the acquired company, but the income tax code provides for some exceptions, including the following:

• On a merger (incorporação), the tax losses of the absorbed company cannot be used by the surviving entity and thus are essentially lost. In a spin-off (cisão), the tax losses of the target entity are lost in proportion to the net equity transferred.
• Carried forward tax losses are forfeited if the company’s ownership and main activity change between the tax period in which the losses are generated and the tax period in which they are used.

Income tax regulations provide that tax losses generated in 1 year can be carried forward indefinitely. However, the use of tax loss carry forwards is limited to 30 percent of taxable income generated in a carry forward year.

Further, capital loss carry forwards may only be used against capital gains. The 30 percent limitation applies here as well.

A gain or loss from the sale of inventory generally is treated as ordinary or operational loss, while a gain or loss from the sale of the machinery and equipment, buildings, land and general intangibles is treated as a non-operational (capital) gain or loss.

Pre-sale dividend

In certain circumstances, the seller may prefer to realize part of the value of their investment as income by means of a pre-sale dividend. The rationale here is that the dividend is currently exempt from taxes in Brazil but reduces the proceeds of the sale and thus the gain on sale, which may be subject to tax. However, each case must be examined on its merits.

Tax clearances

In Brazil, the concept of tax clearance does not exist. Consequently, tax and labor liabilities are only extinguished on expiration of the statute of limitations. Generally, the statute of limitations period is 5 years, beginning with the first day of the period following the taxable event (normally, a tax period comprises a month or a year).

Several potential acquisition vehicles are available to a foreign buyer, and tax factors often influence the choice.

Local holding company

A Brazilian holding company is typically used where the buyer wishes to ensure the tax-deductibility of the goodwill paid or where tax relief for interest is available to offset the target’s taxable profits.

Foreign parent company

The foreign buyer may choose to make the acquisition itself. This does not necessarily cause any tax problems in Brazil, as dividends are currently exempt from WHT. However, Brazil does charge WHT on interest.

Non-resident intermediate holding company

As mentioned earlier, a direct sale of a Brazilian company’s shares by a non-resident is subject to WHT in Brazil where a capital gain is recorded. Until 31 December 2016, the WHT rate was 15 percent. As of 1 January 2017, progressive rates apply as follows:

• 15 percent on the portion of gain up to 5 million Brazil Real (BRL)
• 17.5 percent on the portion of gain between BRL5 million and BRL10 million
• 20 percent on the portion of gain between BRL10 million and BRL30 million
• 22.5 percent on the portion of gain exceeding BRL30 million.

An intermediate holding company resident abroad could be used to defer this tax. However, both buyer and seller should be aware that the Brazilian tax authorities may try to establish whether this intermediate company has a real economic purpose and substance in order to look through the intermediate company and charge the appropriate tax.

Local branch

A Brazilian branch of a multinational company is treated as a regular legal entity in Brazil for tax purposes. A branch is also subject to Brazilian law and courts with regard to business and transactions it carries out in Brazil.

Generally, a business unit (branch) of a foreign company located in Brazil requires prior approval from the federal government by presidential decree, which is a lengthy process. The federal government also must authorize any amendments to the branch’s articles of incorporation.

The power to grant the authorizations may be delegated. Currently, the authorizations must be issued by the Ministry of Development, Industry and Commerce.

Joint venture

Joint ventures are corporate companies (with the joint venture partners holding shares in a Brazilian company). There are no special rules for the taxation of such entities.

From a Brazilian tax perspective, the capitalization of an entity with debt or equity is influenced by the expected profitability of the company. At least for a non-resident shareholder, financing through debt is generally more tax advantageous as interest paid on the debt is fully deductible for Brazilian corporate tax purposes. The potential benefits of an interest deduction may outweigh the WHT burden associated with the interest paid.

Foreign capital must be registered with the BACEN (Law 4131/62). Obtaining the foreign capital registration is of paramount importance because this is the foundation for paying dividends and repatriating capital in foreign currency and, in some cases, it is required to record a tax base in a target company’s shares or assets.

Deductibility of interest

Brazil has thin capitalization rules. Generally, for tax purposes, the debt cannot be higher than:

• two times the amount of the participation of the lender located anywhere outside Brazil (except for lenders located in low-tax jurisdictions or under a privileged tax regime) in the net equity of the borrower
• 30 percent of the net equity of the borrower where the lender is located in a low-tax jurisdiction or under a privileged tax regime (whether a related party or not).

This rule also applies for any kind of debt operation where a foreign related party acts as guarantor, co-signer or intervening party of the debt contract.

This legislation also defines specific requirements that taxpayers must meet to deduct payments to beneficiaries located in a low-tax jurisdiction or under a privileged tax regime. These requirements include identifying the beneficiary owner and determining the operational capability of the foreign party to carry out the operation agreed upon with the Brazilian party.

Withholding tax on debt and methods to reduce or eliminate it

There is a WHT burden of 15 percent associated with the interest paid (25 percent if paid to a tax haven resident).

Equity

Unlike interest, dividends are not subject to WHT when paid to a non-resident.

Additionally, Brazilian tax law (Law 9.249/95) allows a company to elect to pay interest to shareholders as return on equity capital at the official long-term interest rate.

Interest on equity paid or accrued to resident or non-resident shareholders is generally deductible for income tax and social contribution tax purposes. The payment is subject to WHT of 15 percent, as previously noted.

Interest on Equity is calculated by applying the daily pro rata variation of the long-term interest rate (TJLP) to the value of the company’s net equity accounts at the beginning of the year. Increases and decreases in the equity accounts must also be considered in the computation, and the deduction is subject to limitations.

Because of its unique nature, interest on equity payments may be considered as dividend payments in several recipients’ home countries, carrying underlying foreign tax credits or being exempt, while being deductible for Brazilian income tax and social contribution tax purposes.

Corporate reorganization

Generally, corporate reorganizations (e.g. incorporações, fusões and cisões), liquidations and capital contributions — including capital contributions of shares — can be accomplished tax-free in Brazil, as long as assets are transferred at tax book value and other formalities are met.

However, there may be reasons to structure a reorganization as a taxable transaction (e.g. transfer of assets at fair market value). For example, transferring assets as part of a reorganization may allow:

• use of current-year losses that would otherwise become subject to loss limitations
• international tax planning
• a step-up in the tax bases of assets.

Hybrid instruments (i.e. instruments that may have either debt and equity characteristics or that may be treated differently in different jurisdictions) are relatively new to Brazil. They are being used with limited success. Brazil has very flexible tax rules with respect to debt, which makes the creation of hybrid financing instruments possible, but exchange control regulations generally limit the taxpayer’s options.

Company law and accounting

Brazilian generally accepted accounting principles (GAAP) is mainly governed by corporate law (Law 6.404/76) and the basic conceptual framework is provided by the Conselho Federal de Contabilidade (CFC — Accounting Federal Council).

On 28 December 2007, Law 6.404/76 was amended and modified in certain aspects by Law 11.638/07, which is effective from 1 January 2008. One of the main objectives of Law 11.638/07 is to align Brazilian GAAP with IFRS.

The rules and regulations issued by Brazil’s federal securities regulator (CVM) are consistent with international accounting standards adopted in the major financial and capital markets. The implication is that a systematization of new financial reporting standards, applicable to the preparation of financial statements and financial reports in general, gradually will converge to full adoption of IFRS. This convergence, currently in progress, is being coordinated by the Accounting Standards Committee (CPC).

Generally, Brazilian GAAP is based on the accrual method of accounting, unless specific legislation or a rule states otherwise. Inflationary adjustments are not required in financial statements.

Group relief/consolidation

Brazil does not have group relief or tax consolidation rules.

Transfer pricing

In structuring acquisitions and reorganizations, it is important to keep in mind the potential application of Brazil’s tax rules related to transfer pricing and disguised distributions of profits. Generally, these provisions require that Brazilian-resident companies that buy or sell assets, including shares, from or to a related party do so at market value determined according to specific rules. Variations from market value may increase tax or reduce the tax base.

Foreign investments of a local target company

Brazilian controlled foreign company rules (CFC) subject any profits recorded by foreign subsidiaries to tax in Brazil at the end of the year. A foreign tax credit is granted up to the amount of Brazilian tax due on the same profits.

Losses generated by the foreign subsidiary can be offset against future profits generated abroad but not against Brazilian profits.

Advantages of asset purchases

• Buyer usually obtains a step-up in the bases of the assets.
• Where the assets acquired constitute a going concern (acervo de negócios), the buyer may obtain benefits of tax credits and certain other tax attributes, especially those associated with indirect taxes, such as IPI and ICMS.
• May take less time to implement.

Disadvantages of asset purchases

• Tends to result in a more tax burdensome transaction when compared to a share deal (especially for IPI, ICMS, PIS, COFINS and ITBI purposes).
• May prevent the buyer from acquiring the target’s tax losses and other tax attributes.
• From a seller’s perspective, an asset sale may provide much more limited opportunities than a share sale for tax planning to minimize gains on the assets sold.
• Where the assets transferred constitute a going concern (acervo de negócios), some inheritance of liabilities cannot be avoided. The buyer of a going concern generally remains with joint, several or secondary liability for pre- acquisition tax liabilities related to the business acquired, depending on whether the seller continues to operate in the same line of business.
• Depending on the assets or business acquired, acquiring assets may require new registrations for tax, labor and other regulatory purposes, termination costs, re-hiring costs for employees, and other administrative burdens. Brazilian labor and tax laws provide for significant termination costs for employers. In an asset sale, employment technically must be terminated, triggering certain severance costs that can be significant.
• The post-acquisition administrative burden associated with the transfer of the assets or a going concern can be much more significant in an asset sale.

Advantages of share purchases

• Minimization of tax impacts, especially for IPI, ICMS, PIS, COFINS and ITBI purposes.
• Where the transaction is structured properly, the buyer may be able to obtain a better tax result by structuring the acquisition as an acquisition of shares rather than acquiring the assets directly. The benefit is that acquiring shares allows for the recovery of the purchase premium (sales proceeds exceeding book value of the target company) through amortization. The nature of the premium is significant for Brazilian tax purposes, but in most cases, a premium can be recovered over a 5-year period — significantly faster than the recovery period for most fixed assets, which are generally depreciable over 10 years.
• Tax losses and other tax attributes of the target company may be carried over (see ‘Tax losses’ section).
• Where employees are to be transferred with the target business, it may be possible to transfer them with the acquired business without terminating their employment.

Disadvantages of share purchases

• Pre-acquisition tax liabilities of the target remain with the purchased legal entity.
• Where the buyer wants to purchase only part of the target’s business, pre-acquisition structuring steps may take some time to implement.

Ericson Amaral
Head of M&A and International Tax
Brazil
Rua Arquiteto Olavo Redig Campos, 105
6ºth - 12ºth floor - Edifício EZ Towers

T: +55 11 3940 3376
E: eamaral@kpmg.com.br

Marcus Vinicius de Oliveira
Partner
Deal Advisory and M&A Tax
Rua Arquiteto Olavo Redig Campos, 105
6ºth - 12ºth floor - Edifício EZ Towers

T: +55 11 3940 3277
E: moliveira@kpmg.com.br

Carlos Eduardo Toro
Partner
International Tax,
Deal Advisory and M&A Tax
Rua Arquiteto Olavo Redig Campos, 105
6ºth - 12ºth floor - Edifício EZ Towers

M: +44 (0)7500598088 (UK)
M: +55 11 969981618 (Brazil)
E: ctoro@kpmg.com.br

Abilio Machado
Partner
Deal Advisory and M&A Tax
Rua Arquiteto Olavo Redig Campos, 105
6ºth - 12ºth floor - Edifício EZ Towers

T: +55 11 3940 1835
E: abmachado@kpmg.com.br