Tax litigation

Administrative and judicial challenge of tax claims: infringement notices, writs of mandamus, annulment actions and defence in tax enforcement.

Dealings with the tax authorities have short deadlines and severe preclusions. An infringement notice not answered in time becomes a final debt; an unchallenged enrolment becomes enforcement. We act so that the challenge happens at the right moment and with the right evidence.

We act at the administrative level, before judgment offices and taxpayers' councils, and in court, through writs of mandamus, annulment actions and objections to enforcement. We have particular experience in disputes involving foreign trade, the taxation of gold and foreign-exchange transactions.

In Portugal, we handle administrative complaints, judicial challenges and tax inspection procedures, with special attention to dual tax residence between Brazil and Portugal.

How we work

Analysis of the notice with the deadline calendar set on day one.
Reasoned choice between the administrative and the judicial route.
Technical argument, without rhetoric: the evidence and the rule.

Frequently asked questions

Is it worth challenging at the administrative level?

Often, yes: it suspends enforceability without security and allows review by specialised bodies. The decision depends on the matter and the amount.

The state tax authority has summoned my company to regularise its registration. Is it urgent?

Yes. Suspension of the state registration halts the company's activity. The reply deadline is usually short and a writ of mandamus may be necessary.

Do you act for individuals?

Yes, in particular residents abroad, expatriates and heirs with inheritance-tax and income-tax questions on assets in both countries.

Tell us about your matter