Business Law

Tax Recovery

A tax review of the last five years to identify overpaid taxes and turn them into cash, with full supporting documentation.

Practice fronts

  • 01Review and diagnosis
  • 02Recovery and offset
  • 03Security and defense

24 services on this page

How we work

Tax Recovery with a business mindset

Many companies overpay taxes without knowing it: unused credits, tax bases already reduced by the courts, incorrect tax classifications and duplicated withholdings. Tax Recovery identifies these amounts and returns them to the company’s cash.

We review the filings of the last five years, quantify the credits adjusted by the Selic rate and choose the safest route: administrative offset, refund or a lawsuit when the claim depends on a court decision.

Each credit is documented in a supporting file, which reduces the risk of disallowance and prepares the company for audits. With PIS and Cofins abolished in 2027, reviewing credit balances has become urgent.

What we do

Tax Recovery services

24 services led by partners, with defined scope, timeline and fees.

Review and diagnosis

  • Five-year tax review
  • PIS and Cofins credits on inputs
  • Tax classification review (NCM)
  • Single-phase products and tax substitution
  • Withholding tax review
  • Payroll contributions
  • ICMS credit balances
  • Assessment of applicable tax theses

Recovery and offset

  • Offsets through PER/DCOMP
  • Refund and reimbursement claims
  • Tax refund lawsuits
  • Enabling court-recognized credits
  • Court-ordered payments (precatórios and RPV)
  • Use of credits in the transition to CBS and IBS
  • Refund of overpaid ICMS-ST
  • Recovery for Simples Nacional companies

Security and defense

  • Supporting documentation for credits
  • Defense against offset denials
  • Administrative appeals
  • Defense against penalties
  • Support during tax audits
  • Supreme Court and STJ precedents (Themes 69, 962 and others)
  • Credit due diligence in M&A
  • Preventive planning

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Frequently asked questions

Questions about Tax Recovery

How long do I have to recover overpaid taxes?

As a rule, five years from the undue payment, under the National Tax Code. Every month of delay may mean losing credits.

Does tax recovery require a lawsuit?

Not always. When the right derives from the law itself, the offset can be made administratively. Claims still under dispute usually require a lawsuit.

Can Simples Nacional companies recover taxes?

Yes. A common case is single-phase or tax-substitution products on which Simples was paid over revenue that should have been segregated.

Let’s talk about your business.

Start with an assessment of your company’s legal structure.