A company that has operated in Brazil for years almost always has credits to recover or incentives it never implemented. This practice is the execution of that: identify, document and bring it back. This work has produced more than R$ 100 million in tax benefits for Evolua’s clients.
01
Tax Credit Recovery
Tax overpaid in the past five years has a way back.
Plenty of companies pay above what they owe without noticing: wrong classification, inflated tax base, credits that existed and were never taken. The law allows a review of the past five years, and what shows up in that window becomes an offset or a refund.
The work is technical from end to end: identify, document, calculate, file and follow through until the credit lands.
What recovery changes in the cash flow
Offset in the current period
Whenever viable, the credit is offset in the coming filings rather than years from now.
A recurring effect
Fixing what caused the overpayment lowers the monthly bill from then on.
Analysis from the real operation
The review starts from the company’s activity, regime and tax structure, not from a generic thesis.
The full cycle
From the review to the offset, through filing, case follow-up and accounting guidance.
This work has produced more than R$ 100 million in tax benefits for Evolua’s clients.
02
Tax Incentives
An incentive written into law and never used is money left on the table.
A tax incentive is a mechanism written into law to encourage a sector, a product or an activity: exemptions, rate reductions, extra deductions, tax credits. They exist in innovation, technology, exports and regional development, among others. What is usually missing is someone checking whether the company qualifies.
Why it is worth looking
A lower bill, still inside the law
The incentive is the statute itself, applied to the company’s case.
Criteria by sector and activity
Each incentive has its own qualifying rule; the real saving shows up when the rule matches the operation.
Confidence in the filing
Documented application, with the reasoning ready for the day it is questioned.
03
Special Tax Regimes
A different tax condition changes margin, timing and routine.
A special regime is an authorization, state or federal, for a company to calculate or pay tax differently from the general rule. It serves development policy and sector specifics, and when it fits the operation it changes margin, cash flow and internal workload.
What a special regime can change
The burden on specific operations
COMPETE-ES, for instance, reduces the ICMS load for companies based in Espírito Santo.
The filing routine
The ICMS-ST special regime in Paraná simplifies calculation and payment for products under tax substitution.
The fit to the company
Application is calibrated to the economic and operating profile, which is why the same regime plays out differently in two companies.
The work runs from assessing eligibility to handling the request before the competent authority, through implementation and upkeep of the conditions the regime depends on.
04
Defense against Infraction Notices
An assessment received is the start of an argument, not the end of the line.
An infraction notice is how the tax authority formalizes an irregularity it found: tax not paid as it should have been, or an ancillary obligation missed. The defense is the set of measures showing the demand is undue, disproportionate or unfounded, and the clock starts running the moment the company is served.
Administrative defense
Review of the notice, the notifications and the demands, with challenges, statements of disagreement and appeals filed directly with the tax authority’s adjudicating bodies.
Judicial defense
Once the administrative route is exhausted, the dispute moves to the courts (federal appellate courts, the STJ and the STF) to suspend undue demands, annul the assessment and preserve the company’s rights.
What a good defense preserves
Assets
Undue freezes and enforcement avoided while the dispute runs.
The argument
Built on the law and case law as they stand today, not as they once stood.
The liability
The debt reduced or extinguished when the demand doesn’t hold up.
A manufacturer under the actual profit regime started selling a new product with full PIS/COFINS. A periodic tax review of the item's classification showed a technical alternative: an NCM code carrying a zero PIS/COFINS rate.
