Partner

• May 2022 - Present

Partner responsible for the Tax Consultancy department, focused on tax consultation, M&A tax, tax advice for corporate and capital market transactions, tax planning, international taxation, transfer pricing, private wealth planning. Main industries: Real Estate, Civil Construction, Agribusiness, Technology & Techs, Digital Economy, Pharmaceuticals, Manufacturers, Financial Services, Audivisual & Entertainment. (Direito Tributário - Consultoria Tributária - Consultivo - Planejamento Tributário) Show less

Visiting Professor

• Aug 2022 - Present

Professor of the course "Tax Planning" at the LL.M. in Taxation Professor of the course "Tax Planning" at the LL.M. in Taxation

Visiting Professor

• Mar 2021 - Present

Visiting Professor of the course "IOF-Tax" the LL.M. in Taxation at IBMEC-Rio Visiting Professor of the course "IOF-Tax" the LL.M. in Taxation at IBMEC-Rio

Visiting Professor

• May 2018 - Present

Professor of the Post-Graduation Course (Especialização em Direito Tributário) of the FDV Professor of the Post-Graduation Course (Especialização em Direito Tributário) of the FDV

Member

• Jan 2018 - Present

Visiting Professor

• Apr 2017 - Present

Professor of the MBA in Tax Management (MBA GT) - courses "Tax Planning: Case Law" and "Federal Tax Incentives"; and in the MBA Controller, teaching the course: "Business Law". Professor of the MBA in Tax Management (MBA GT) - courses "Tax Planning: Case Law" and "Federal Tax Incentives"; and in the MBA Controller, teaching the course: "Business Law".

Visiting Professor

• Nov 2013 - Present

Professor in the Post-Graduation in International Taxation at IBDT/USP, teaching the classes: (i) Article 4 of OECD MC & US Model Treaty - Residence in Double Tax Treaties; and (ii) Beneficial Owner Concept in Double Tax Treaties. Professor in the Post-Graduation in International Taxation at IBDT/USP, teaching the classes: (i) Article 4 of OECD MC & US Model Treaty - Residence in Double Tax Treaties; and (ii) Beneficial Owner Concept in Double Tax Treaties.

Visiting Professor

• Nov 2013 - Present

Visiting Professor of the (i) Post-Graduation in Tax Planning & Corporate Transactions; and (ii) MBA in International Taxation & Negotiation; teaching the following courses: - Taxation of Capital & Financial Markets; - International Taxation (OECD Model Convention); - International Private Wealth Planning (Trusts & Foundations Tax Planning); - Corporate Income Taxes - Offshores, Holdings and Tax Havens - Transfer Pricing - Tax Planning Visiting Professor of the (i) Post-Graduation in Tax Planning & Corporate Transactions; and (ii) MBA in International Taxation & Negotiation; teaching the following courses: - Taxation of Capital & Financial Markets; - International Taxation (OECD Model Convention); - International Private Wealth Planning (Trusts & Foundations Tax Planning); - Corporate Income Taxes - Offshores, Holdings and Tax Havens - Transfer Pricing - Tax Planning

Professor da Graduaçao - “Legislaçao e Contabilidade Tributarias”

• Jan 2019 - Jan 2023

Professor CLTista do curso de Graduaçao em Ciencias Contabeis para Graduados (CPG), titular da disciplina: “Legislaçao e Contabilidade Tributarias” - carga horaria semanal de 04 horas/aula Professor CLTista do curso de Graduaçao em Ciencias Contabeis para Graduados (CPG), titular da disciplina: “Legislaçao e Contabilidade Tributarias” - carga horaria semanal de 04 horas/aula

Partner

• Apr 2019 - Mar 2022

Founding Partner of the tax boutique BUENO & CASTRO TAX LAWYERS, a law firm exclusively devoted to Tax Law, with accounting skills and international experience - both academic and professional - acquired in the U.S. (Washington D.C. and New York City) by its founding partners. Visit out website www.buenoecastro.tax Founding Partner of the tax boutique BUENO & CASTRO TAX LAWYERS, a law firm exclusively devoted to Tax Law, with accounting skills and international experience - both academic and professional - acquired in the U.S. (Washington D.C. and New York City) by its founding partners. Visit out website www.buenoecastro.tax

Visiting Professor

• Sep 2012 - Nov 2020

Visiting Professor of the Post-Graduation course on International Tax Law ("DTI"), teaching the classes (i) "Brazilian Case Laws on International Tax" and (ii) "Permanent Establishments". Visiting Professor of the Post-Graduation course on International Tax Law ("DTI"), teaching the classes (i) "Brazilian Case Laws on International Tax" and (ii) "Permanent Establishments".

Conselheiro Julgador

• May 2018 - May 2020

Substitute administrative tax judge at the Municipal Tax Counsel of Sao Paulo for the 2018-2020 biannual term Substitute administrative tax judge at the Municipal Tax Counsel of Sao Paulo for the 2018-2020 biannual term

Judge

• Jan 2014 - Dec 2019

Substitute Administrative Judge for the 2014/2015 & 2016/2017 terms, representative of taxpayers, at the Administrative Tax Court of the State of São Paulo (TIT/SP), which rules on State tax issues such as ICMS, ITCMD and IPVA (i.e., VAT, gift and estate tax and automotive property tax) previously to the claim being filed at judicial level. Substitute Administrative Judge for the 2014/2015 & 2016/2017 terms, representative of taxpayers, at the Administrative Tax Court of the State of São Paulo (TIT/SP), which rules on State tax issues such as ICMS, ITCMD and IPVA (i.e., VAT, gift and estate tax and automotive property tax) previously to the claim being filed at judicial level.

Assistant Teacher

• Feb 2016 - Jul 2019

Assistant Teacher to Prof. Gerd Rothmann at the LLM/PhD program at University of Sao Paulo Law School (USP-FD), teaching the course "BEPS - Base Erosion and Profit Shifting" for the 2016.1 semester; "Tax Principles" for 2017.1; "Interpretation of Tax Legislation" for 2017.2 Assistant Teacher to Prof. Gerd Rothmann at the LLM/PhD program at University of Sao Paulo Law School (USP-FD), teaching the course "BEPS - Base Erosion and Profit Shifting" for the 2016.1 semester; "Tax Principles" for 2017.1; "Interpretation of Tax Legislation" for 2017.2

Partner - Tax

• May 2017 - Apr 2019

Partner of Costa Tavares Paes Advogados (CTP), Head of the Tax Consultancy practice of the firm and responsible for the Tax Department in the São Paulo office. Main practices include tax planning, international taxation, foreign investments structuring, transfer pricing, customs & VAT, private wealth planning, mergers & acquisitions, structured finance transactions, corporate law, contracts, real estate and legal opinions on tax, corporate and business reorganizations. Partner of Costa Tavares Paes Advogados (CTP), Head of the Tax Consultancy practice of the firm and responsible for the Tax Department in the São Paulo office. Main practices include tax planning, international taxation, foreign investments structuring, transfer pricing, customs & VAT, private wealth planning, mergers & acquisitions, structured finance transactions, corporate law, contracts, real estate and legal opinions on tax, corporate and business reorganizations.

Coordinator of Tax Committee

• May 2013 - Nov 2017

One of the three coordinators of the Tax Committee of the IBRADEMP, responsible for organizing tax pannels, conferences and events related to business taxation and corporate/capital market taxation. One of the three coordinators of the Tax Committee of the IBRADEMP, responsible for organizing tax pannels, conferences and events related to business taxation and corporate/capital market taxation.

International Tax Senior Manager

• Jun 2015 - May 2017

Senior Manager of International Tax Services (ITS), advising multinational clients on cross-border tax issues (inbound & outbound), specially related to international tax planning, corporate reorganizations, double tax treaties, transfer pricing, global compliance, VAT, private wealth planning and customs duties. Activities include: cross-border structuring and assistance in corporate reorganizations, change of residence for individuals, company migration, regional supply chain structuring and LATAM investments - tax advice and implementation, as well as Tax Opinions on complex international tax matters and local Brazilian tax issues Show less

Senior Associate (Tax)

• Jan 2013 - Jun 2015

Senior Associate and Head Coordinator at the Tax Consultancy & International Tax Practice. -Provide detailed tax analysis regarding new products/ventures, identify related tax risks and suggest potential mitigation factors; -Support clients design and structure tax efficient deals, identifying potential tax issues and risks, as well as suggesting potential solutions and/or mitigation factors; -Assist business/operational/finance teams regarding tax related operational issues arising from the day-by-day activities; -Advise on business structure cross border products/activities and/or global transactions/investmetns interacting with client's staff and professionals in other locations and practice areas worldwide -Engage and interact with client's tax & finance teams, both locally and worldwide -Participating in meetings and calls to discuss with market peers and client's staff in order to reach understanding regarding changes and/or unclear tax & legal matters affecting client's business in Brazil and abroad -Provide clients with tax related international and Brazilian tax advice in order to implement new processes and/or produts - Coordinate implementation in case of tax related projects inbound & outbound and provide post-implementation support/guidance from the tax perspective -Draft Legal Opinions and Memorandum to support clients' business decisions from a tax law perspective, and review/draft contracts to adapt tax consequences of the deal/transaction Main Areas: Inbound and outbound structuring/ Cross-border tax advice/ Controlled foreign companies (CFC) tax planning/ Subpart F / Profit repatriation/ Loss utilization/ Foreign Tax Credit (FTC) advice/ Transfer Pricing (OECD Guidelines, US § 482; Brazil Law No. 9,430/96)/ Double Tax Treaties/ Tax Accounting (US GAAP/IFRS/ BR GAAP – FIN 48, CPC 15, etc.)/ Comparative Tax Knowledge on Foreign Tax Structures (Luxemburg, Netherlands, Austria, US, Ireland, BVI, Cayman, Spain, UK)/ FATCA & FBAR Show less

Visiting Professor

• Aug 2012 - Jan 2015

Visiting Professor of the Post-Graduation in Business Taxation course, teaching the 3-class course of "International Taxation". Visiting Professor of the Post-Graduation in Business Taxation course, teaching the 3-class course of "International Taxation".

Visiting Professor

• Jul 2008 - Jan 2015

Visiting Professor of the MBA in Foreign Trade & International Commerce (PROCEBE) of FIA/USP, teaching the classes (i) taxation of foreign trade: import & export; (ii) transfer pricing; (iii) international tax planning; and (iv) double tax treaties, thin cap rules & CFCs. Visiting Professor of the MBA in Foreign Trade & International Commerce (PROCEBE) of FIA/USP, teaching the classes (i) taxation of foreign trade: import & export; (ii) transfer pricing; (iii) international tax planning; and (iv) double tax treaties, thin cap rules & CFCs.

Tax Section National Reporter for Brazil

• Jun 2012 - May 2014

The IBA Tax Section generally designates one National Reporter from each country. National Reporters are required to write an annual report that describes the major tax developments in their country over the past year, which are published on the IBA's website. They are also invited to speak at IBA's Annual Conference. National Reporters serve for 2-year terms (2012-2014). The IBA Tax Section generally designates one National Reporter from each country. National Reporters are required to write an annual report that describes the major tax developments in their country over the past year, which are published on the IBA's website. They are also invited to speak at IBA's Annual Conference. National Reporters serve for 2-year terms (2012-2014).

Associate Lawyer

• Aug 2011 - Jul 2012

Global Securities and Global Project Finance. - Represented major financial institutions acting as issuers, investors and underwriters in cross-border transactions, with an emphasis on debt offerings under Rule 144A and Regulation S; - Provided advice on U.S. broker-dealer laws, including the Securities Exchange Act of 1934 and FINRA rules; - Represented lenders in syndicated, unsecured revolving credit facilities for domestic cooperatives; - Represented international lenders on a project financing in Brazil for the construction of 3 airports worldwide; - Represented Brazilian company in connection with the US$ 400 million sale all its overseas logistics assets in a cross-board M&A deal; - Contribute and liaise with the other legal teams from other Practice Groups; -Assist in the specification, design and mapping of operational process for issuance of Offering Memorandum (NY Law deals) and Prospectum (Brazilian deals) in Securities/Capital Market offerinngs - Provide post-implementation support/guidance from the NY securities law & corporate law perspective; - Drafted, Reviewed and Amended agreements on Project Finance deals both for US and Brazilian clients; - Interacted and coordinated legal assistants, trainees and summer associates in those practices groups; - Volunteered in pro-bono tax cases involving U.S. tax issues Main Areas: US Securities (SEC, FINRA)/ Global Project Finance/ NY Corporate Law/ Brazilian Capital Markets (CVM)/ Brazilian Contracts Show less

Senior Associate - Tax Consultancy Group

• Feb 2008 - Aug 2010

Tax Consultancy & Foreign Investments Tax Practice - Advised clients by drafting Legal Opinions and Memoranda on tax and customs issues related to foreign investments and structures in Brazil; legal assistance on local and international tax planning, import/export, transfer pricing and tax treaties; - Provided legal assistance on taxation issues related to merger & acquisitions, capital markets, private equity and venture capital funds; - Assisted private clients on wealth management issues and international tax structures and assets reorganization for Brazilian individuals and expatriates. - Coordinated junior associates and trainees in the tax department. Main Areas: Brazilian Tax Law/ International Taxation/ Tax Planning/ Tax Treaties/ Transfer Pricing/ Corporate Law/ Contracts/ Constitutional Law/ Private Wealth Planning (inbound & outbound) Show less

Professor of Tax & Accounting Planning at B.A. in Accounting

• Feb 2010 - Jul 2010

Professor of the course "Tax & Accounting Planning" in the B.A. in Accounting at Trevisan Business School in Sao Paulo, Brazil, permanently hired, for a class of 35 students, once a week during the semester. Professor of the course "Tax & Accounting Planning" in the B.A. in Accounting at Trevisan Business School in Sao Paulo, Brazil, permanently hired, for a class of 35 students, once a week during the semester.

Assistant Teacher of Tax Law (PAE Program)

• Feb 2010 - Jun 2010

Assistant Teacher of Tax Law enrolled through the Professional Development Program (PAE) of the University of Sao Paulo Law School (FD USP), under the coordination of Prof. Gerd Willi Rothmann (PhD Professor), after due selection process, receiving a credit with maximum grade ("A" grade) after completion. Assistant Teacher of Tax Law enrolled through the Professional Development Program (PAE) of the University of Sao Paulo Law School (FD USP), under the coordination of Prof. Gerd Willi Rothmann (PhD Professor), after due selection process, receiving a credit with maximum grade ("A" grade) after completion.

Associate Lawyer - Tax & Corporate

• Feb 2007 - Feb 2008

Coordinator of Tax Consultancy and Tax Litigation Group; also working in the Contracts & Trade Finance Groups. 1) Tax Department: - Advised clients on tax and customs issues in Brazil, implementing and assisting on international and local tax structures for foreign investors. - Drafting tax claims and defenses and managing tax litigation issues related to clients, on Federal, State and Municipality level, both on Judicial and Administrative Courts. 2) Corporate Deparment: - Drafting of corporate documents and contracts, foreign investment assistance at Brazilian Central Bank and at Brazilian Securities and Exchange Commission (CVM), working with articles of association of corporations (S.A.) and limited liability companies (LTDA). - Acted as legal council for local and international companies in merger & acquisitions, spin offs and international finance and trade finance transactions. Main Areas: Tax Consultancy / Tax Litigation (Administrative & Judicial)/ Foreign Investments / Trade Finance / Banking Law/ Commercial Contracts / Agribusiness Legal Issues / PRivate Wealth Planning (inbound & outbound) Show less

Assistant Teacher of Tax Law I & Financial Law

• Jul 2006 - Dec 2006

Assistant teacher, appointed by PUC-Rio Law School through selective process, of the course "Tax Law I and Financial Law" taught on the J.D. level. Assistant teacher, appointed by PUC-Rio Law School through selective process, of the course "Tax Law I and Financial Law" taught on the J.D. level.

Trainee - Tax Consultancy Department

• Jul 2005 - Aug 2006

Drafted Legal Opinion and Memos and assisted in research on tax and customs issues related to local and international taxation in Brazil. Prepared administrative tax defenses in Federal, State and Municipality administrative courts. Drafted Legal Opinion and Memos and assisted in research on tax and customs issues related to local and international taxation in Brazil. Prepared administrative tax defenses in Federal, State and Municipality administrative courts.

Trainee - Project Finance & Oil/Gas Department

• Feb 2004 - Jul 2005

Provided legal assistance in structuring and developing oil & gas upstream and downstream projects, including the drafting, negotiation and reviewing of contracts such as Participation Agreements; Engineering and Procurement Contact, and other corporate documents. Provided legal assistance in structuring and developing oil & gas upstream and downstream projects, including the drafting, negotiation and reviewing of contracts such as Participation Agreements; Engineering and Procurement Contact, and other corporate documents.