Marcelo Salles Annunziata
Agribusiness Automotive Aviation Chemical and Petrochemical Sports and Entertainment Tax
+55 11 3356 2187 mannunziata@demarest.com.br São Paulo
Partner in Demarest’s Tax area, Marcelo Salles Annunziata holds a Master’s degree in Tax Law from USP and a specialization in Civil Procedural Law from PUC-SP. He is the author of several academic studies published in some of the most highly regarded journals in the country including some of the most important media vehicles. Marcelo is a professor of Tax Law in preparatory courses for public examinations and has lectured frequently on the most important topics in the area. With a practice focused mainly on judicial litigation, he has been cited for many years as a “leading lawyer in his field” by Chambers, Leaders League, Latin Lawyer 250, International Tax Review, and more recently by Legal 500, Who’s Who Legal and Análise Advocacia 500.
- Advised Chevron Oronite in a major legal dispute for the cancellation of a PIS debt.
- Advised Telefônica in relation to the adhesion to a special installment payment program of the Federal Government.
- Advised Tullet in obtaining an injunction that was able to prevent the application of Normative Instruction No. 1.862/18 of the Federal Revenue Office regarding the imputation of liability to the partners and managers of legal entities.
- Advised HDI in tax audits and in the defense of four tax notices, currently amounting to approximately BRL 270 million.
- Assistance to clients regarding the offsetting of credit for a judicial decision that recognized the right to exclude ICMS from the PIS and COFINS tax basis; and filing a judicial measure in order to ensure that such credit is taxed by IRPJ and CSLL only at the time of approval of the offsetting declarations.
- Master’s degree in Tax Law from the University of São Paulo (USP), São Paulo, Brazil (2002)
- Specialization in Civil Procedural Law from the Pontifical Catholic University of São Paulo (PUC-SP), São Paulo, Brazil (1998)
- Bachelor of Laws from the University of São Paulo (USP), São Paulo, Brazil (1994)
- Member of the Institute of Tax Research (IPT)
- Member of the Institute of Fiscal Policy (IPF)
- Author of the article “Agenda Tributária de 2019” [“Tax Agenda of 2019”], O Estado de São Paulo, March 2019.
- Author of the article “Agravo em Recurso Especial e a nova jurisprudência defensiva do STJ” [“Injunction in Special Appeal and the new case law of the STJ”], Portal JOTA, March 2019.
- Author of the article “Fiança e Seguro Garantia: abrangência atual, aspectos em comum e diferenças” [“Surety Bond and Insurance Bond: current scope, common aspects and differences”], in Garantias Judiciais no Processo Tributário [Judicial Guarantees in Tax Proceedings], Editora Blucher, 2018.
- Author of the article “Custo Ilegal nas Importações” [“Illegal Costs on Imports”], O Estado de São Paulo, March 2018.
- Author of the article “Execução Fiscal” [“Fiscal Execution”], portal JOTA, December 2017.
- Author of the article “Substituição do Depósito em Dinheiro por Seguro Garantia” [“Replacement of the Cash Deposit with Insurance Bond”], portal JOTA, May 2017.
- Author of the article “Multa isolada em compensação tributária – ilegitimidade dos lançamentos prematuros efetuados pela Receita Federal do Brasil” [“Isolated fines in tax offset – illegality of the premature assessments made by the Federal Revenue Office”], Migalhas, March 2017.
- Author of the article “Novo CPC: decisões polêmicas contra a Fazenda Pública” [“New CPC: controversial decisions against the Public Treasury”], portal JOTA, March 2017.
- Author of the article “Reflexos da compensação de estimativas de IR e CSLL na apuração de saldo negativo” [“Impacts of the offsetting of IR and CSLL estimates in the determination of negative balance”], O Estado de S. Paulo, February 2017.
- Author of the article “Denúncia espontânea na compensação tributária” [“Voluntary disclosure in tax offsetting”], Valor Econômico, September 2016.
- Portuguese, English and Spanish
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