Advisory & International Taxation

Structuring, optimization, and tax governance for global operations

Infis Consulting supports companies in structuring, expanding, and managing international operations with a focus on tax efficiency, regulatory compliance, and risk mitigation.

Our Advisory & International Taxation practice combines strategic insight, up-to-date technical expertise, and practical execution to support complex decision-making in cross-border environments.

Cross-Border Operations

We support companies in the full analysis of their international structures, promoting tax efficiency and legal certainty. Services include:

Mapping of international flows (products, services, intangibles, and financial transactions)

Identification of tax and regulatory risks

Forward-looking tax planning for international expansion

Optimization of operational and corporate structures

Review of double taxation treaties

Structuring of supply chains and shared service centers

Transfer Pricing (New Brazilian Rules)

With Brazil’s convergence to OECD standards, we support companies in adapting to the new transfer pricing regime. Services include:

Impact assessment of the new legislation

Economic studies

Local file and master file documentation

Review of intercompany contracts

Definition and implementation of transfer pricing policies

Adaptation of operational models to the arm’s length principle

Support in audits and disputes

OECD Initiatives – Pillar 2 (Global Minimum Taxation)

We help your company prepare for the new global tax environment. Full scope services in:

Scope assessment and classification

Calculation of the Effective Tax Rate (ETR) by jurisdiction

Assessment and application of safe harbors

Preparation of regulatory reporting

Calculation of top-up tax (additional CSLL)

Financial impact modeling

Structuring of compliance and governance processes

Business Combination Advisory

Strategic and tax support in corporate reorganizations and transactions. Includes:

M&A Tax Structuring

Modeling of mergers, spin-offs, and corporate reorganizations

Planning and utilization of goodwill

Purchase Price Allocation (PPA) with a tax perspective

Optimization of the tax impacts of goodwill and asset step-ups

Post-transaction review and tax integration

Repatriation and Capital Flow Structuring

We structure international financial flows in an efficient and secure manner. Services include:

Planning of profit distribution, interest, and dividends

Structuring of intercompany financing

Optimization of withholding taxes (WHT)

Planning of subsidiary capitalization

Structuring of international and back-to-back loans

Tax management of cross-border remittances

Foreign Exchange Market and Regulation (Central Bank – BACEN)

We support companies in navigating Brazil’s foreign exchange regulatory environment, ensuring compliance and tax efficiency. Services include:

Tax planning of FX operations focused on IOF optimization

Structuring of international financial flows under regulatory oversight

Foreign investment registration (RDE-IED)

Financial operations registration (RDE-ROF)

Support for external loan transactions

Compliance review with Central Bank regulations

Support with contracts and FX documentation

Financing Planning for Operations in Brazil

We structure efficient local and international financing models, considering all tax and regulatory impacts.
Services include:

Definition of optimal capital structures (debt vs. equity)

Tax planning for local and cross-border financing

Optimization of IOF, withholding income tax (IRRF), and other applicable taxes

Assessment of transfer pricing and thin capitalization impacts

Structuring of hybrid and intercompany instruments

Modeling of effective financing cost (after-tax)

Review of contracts and financial terms

Ready to simplify your accounting and tax routine?

Schedule a conversation with our specialists and discover how INFIS can optimize processes, reduce costs, and free up your team to focus on business growth.