About Cecília Santoro

Cecília Santoro is a Brazilian lawyer with over twenty years of experience advising multinational companies in sectors such as oil and gas, construction, food and beverage, chemical, pharmaceutical, medical products, packaging, technology, commerce, and logistics. Her experience is predominantly in Brazilian Public Law with a focus on tax, customs, bids & public contracts. Cecília has deep and solid knowledge of the Brazilian tax system, recognized as one of the most complex in the world today. Cecília also led projects related to bids, public tenders, and public contracts before the Brazilian government. Complimenting her international and tax background, Cecília also has substantial customs law experience–having advised on large projects involving imports of raw materials, goods, and services. Cecília’s career includes time with prominent Brazilian law firms as well as a role as an in-house legal manager. As an in-house legal manager, Cecília was at the forefront of large complex projects of high strategic relevance requiring creative planning.

  • Led project to restructure import operations related to the energy sector, which mitigated legal risks, made the process legally safer, in accordance with Brazilian regulations, and less burdensome in terms of taxes, bringing direct financial results.
  • Strategic lobby before administrative courts in defense of the company’s recurring operation on energy matters that resulted in cancellation of infraction notices, repetition of indebtedness and mitigation of future impositions.
  • Led discussion on the constitutionality of TUST and TUSD (specific taxes on energy sales).
  • Developed special defense strategy before the Federal Court of Auditors in bidding processes in the energy sector.
  • Advised on PETROBRAS fuel acquisition projects and was at the forefront of several suspensions of bids due to legal irregularities.
  • Advised on legal regularity for the operation and commercialization of Biofuels.
  • Led judicial discussion that pointed to the unconstitutionality of the TSA (tax on customs services). The Supreme Court recognized the unconstitutionality which resulted in repetition of undue debts up to ten years.
  • Lead Counsel of innovative and winning defense on antidumping imposition that broke with established precedent in the courts. The new thesis was based on a systemic interpretation of the General Agreement on Tariffs and Trade (GATT 1947) and Brazilian law.
  • Legal representation of importers by special regimes towards the removal of ICMS on temporary admissions.
  • Development of specific tax planning projects for each company, reviewing incidences of IPI, ICMS, ISS in the production chain, as well as calculation of IRPJ, PIS and COFINS.
  • Creation, structuring and leadership of the Public Law department, developing special expertises in tax, customs, regulatory and bidding laws.
  • Developed methodology to serve companies with large backlogs of lawsuits that highlighted hidden financial impacts, turning point between recurring and strategic values, and intelligent reanalysis of provisions.
  • Direct legal advisory to senior management positions of medium and large multinational companies, publicly traded and privately held companies, assisting in executive decisions and supporting strategic decisions.
  • Tax planning, direct and indirect taxes, income tax, VAT, tax obligations and lawful reduction of tax burden, tax compliance, fiscal regularity (CND/CPEN), consultancy in real and presumed profit, identification and mitigation of legal risks, wealth management
  • Legal assistance on highly complex tax matters in federal (IRPJ PIS COFINS IPI II IE) state (ICMS ITCMD) and municipal (ISS IPTU ITBI) taxes, on tax and fiscal audits
  • Administrative and tax customs advice: clearance for definitive/temporary import/export, anti-dumping measures, special regimes, drawback, ex-tariff, warehouse, tax reclassification, NCM, and various tax discussions
  • Management of strategic lawsuits portfolios based on cutting-edge and highly complex discussions, with development of specific strategies for each case.
  • Management of extensive lawsuits portfolios of recurrent matters, tax thesis with development of new legal approaches
  • Legal counselling on customs matters, such as: definitive/temporary import/export clearances, special regimes, drawback, anti-dumping measures, ex-tariff, warehouse, tax reclassification, NCM, and various tax discussions in international trade
  • Planning and legal advice on M&A operations (due diligence, hidden liabilities, EBITDA / EBITDA) and creation of holding companies.
  • Planning and structuring of compliance, legal operations and controllership policies
  • “360 analyses” of legal liabilities, control and analysis of provisions, risk management and compliance with internal policy
  • Expertise in administrative legislation and demands before regulatory agencies (ANP, ANTT, ANATEL, ANEEL, CODECON) and relationship with different bodies (Customs, SECEX, ZFM) and product certification.
  • Litigation before Superior Courts and Administrative Courts (CARF, TIT), federal, state, and municipal
  • Team management: training, guidance, and leadership, with a focus on developing strategies
  • Development of in-company training,
  • Third Sector: tax immunity for private initiatives of public utility, philanthropies, and foundations
  • Legal advice on highly complex public contracts
  • Tenders and Bids: legal analysis, compliance with requirements, objections, defenses and various manifestations
  • PETROBRAS Tenders and Bids
  • Pro bono practice attending elderly women in poverty and in need of legal aid.
  • J.D. Pontifical Catholic University of Campinas
  • LL.M. (Tax Law) Pontifical Catholic University of São Paulo
  • LL.M. (Contract Law), Pontifical Catholic University of Campinas
  • MBA (Tax Management), University of São Paulo
  • Advanced European Union Law, King’s College London
  • Masters Program (International Relations), Universidade Estadual de Campinas
  • Portuguese (native)
  • English (fluent)
  • Spanish (basic)
  • Italian (basic)
  • Brazil
  • Chosen by Leader Editor as one of the “Women in Tax Law” – an editorial project that selected 25 top Tax Lawyers in Brazil.
  • Thirteen chapters of law books published and registered at the National Library/ISBN
  • SANTORO, A. C. P. “Tax civil action” In: Execução Fiscal – Teoria e Prática ed.Leme : Editora Parizatto – EDIPA, 2011, p. 557-565. ISBN: 9788587101907
  • SANTORO, A. C. P. “Interlocutory Appeal on tax foreclosure” In: Execução Fiscal – Teoria e Prática ed.Leme : Editora Parizatto – EDIPA, 2011, p. 389-400. ISBN: 9788587101907
  • SANTORO, A. C. P. “State Administrative Defense” In: Execução Fiscal – Teoria e Prática ed.Leme : Editora Parizatto – EDIPA, 2011, p. 580-584. ISBN: 9788587101907
  • SANTORO, A. C. P. “Tax Execution Procedure in Practice” In: Execução Fiscal – Teoria e Prática ed.Leme : Editora Parizatto – EDIPA, 2011, p. 413-429. ISBN: 9788587101907
  • SANTORO, A. C. P. “Defense on illegal tax execution procedure” In: Execução Fiscal – Teoria e Prática ed.Leme : Editora Parizatto – EDIPA, 2011, p. 430-437. ISBN: 9788587101907
  • SANTORO, A. C. P. “Writ of Mandamus” In: Execução Fiscal – Teoria e Prática ed.Leme : Editora Parizatto – EDIPA, 2011, p. 510-513. ISBN: 9788587101907
  • SANTORO, A. C. P. “Federal Administrative Defense on illegal taxation” In: Execução Fiscal – Teoria e Prática ed.Leme : Editora Parizatto – EDIPA, 2011, p. 585-586. ISBN: 9788587101907
  • SANTORO, A. C. P. “Federal Administrative Defense on debt compensation” In: Execução Fiscal – Teoria e Prática ed.Leme : Editora Parizatto – EDIPA, 2011, p. 587-589. ISBN: 9788587101907
  • SANTORO, A. C. P. “Interlocutory Appeal on overrulled deposit of assets” In: Prática Forense.8a. ed.Leme : EDIPA – Editora Parizatto, 2008, v.2, p. 1428-1435. ISBN: 9788587101518
  • SANTORO, A. C. P. “Tax Execution Procedure in Practice” In: Prática Forense.8a. ed.Leme : Editora Parizatto, 2008, v.2, p. 1440-1450. ISBN: 9788587101518
  • SANTORO, A. C. P. “Defense on illegal tax execution procedure” In: Prática Forense.8a. ed.Leme : Editora Parizatto, 2008, v.2, p. 1450-1455. ISBN: 9788587101518
  • SANTORO, A. C. P. “ISS or ICMS? A costly question”. Artigo jurídico. Rio de Janeiro:Pharma Nostra, 2011.
  • SANTORO, A. C. P. “ISS or ICMS? A question that costs a lot – Part II”. Campinas:Pharma Nostra, 2011.

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