Brazil Brief | Legal Certainty, Taxation, and Compliance: Executing the Commercial Strategy

Amid the opportunities created by the opening of new markets, Brazil’s expansion in international trade cannot rely solely on the signing of bilateral agreements or on increased investment in infrastructure. In an environment where tariffs and non-tariff barriers are increasingly used as instruments of economic policy, the legal framework governing operations becomes a central element of competitiveness.

The effectiveness of tariff benefits depends on strict compliance with rules of origin, accurate tax classification, and full traceability throughout the production chain. “The tariff benefit is not automatic.  Signing the agreement is only the starting point.  The structure of the operation must be adapted to the technical and customs requirements,” says Paloma Amorim da C. Rosa, partner in the Tax & Customs practice at Vieira Rezende.

At the same time, compliance instruments are becoming increasingly integrated into companies’ strategic frameworks.  The Authorized Economic Operator (AEO) program, implemented by Brazil’s Federal Revenue Service, for example, signals the country’s alignment with international best practices for secure and efficient trade. Certified companies operate with greater predictability and in closer alignment with global compliance standards.

Tax reform is part of this broader process of institutional rationalization.  Although the transition period requires adjustments, the stated objective is to simplify consumption taxation, reduce long-standing distortions, and bring the Brazilian tax system closer to international practices. Alongside customs modernization and the negotiation of new trade agreements, the country is seeking to build a more transparent business environment that is compatible with global value chains.

In a global landscape increasingly marked by fragmentation and selectivity, trade agreements, infrastructure development, and regulatory architecture can no longer be treated as separate agendas. Instead, they form part of an integrated strategy for international engagement. By aligning trade policy, institutional modernization, and legal certainty, Brazil not only expands market access but also strengthens its role as a stable and, in many respects, more reliable link between major economic centers. The opportunity is clear. The decisive factor will be the ability to structure it with technical precision, institutional coordination, and a long-term vision.

FOREIGN DESKS AND ECONOMIC DIPLOMACY IN PRACTICE

The intensification of trade relations between Brazil and its European partners is also reflected in Vieira Rezende’s international structure. The firm maintains desks dedicated to strategic jurisdictions within the evolving context of regulatory integration and expanding investment flows between Mercosur and Europe.

The Dutch Desk, led by partner Camila Borba Lefèvre, monitors investments by Dutch companies that use Brazil as a productive and logistical platform for regional operations.  Given the Netherlands’ central role as a commercial gateway to the European Union, coordination between the legal frameworks of both markets becomes a key factor in the effective implementation of cross-border operations.

The French and Norwegian desks operate in a coordinated manner in sectors with significant strategic overlap.  The French Desk, led by partner Bernardo Mendes Vianna, focuses on energy, infrastructure, maritime, and oil sectors—areas that have historically been central to the economic relationship between Brazil and France and that continue to play a prominent role in the bilateral investment agenda. The Norwegian Desk, led by partner Daniela Davila, concentrates on the energy, oil and gas, and offshore sectors, bringing strong technical expertise to these sectors. Since 2011, the firm has maintained an institutional partnership with the Norwegian law firm Wikborg Rein, which provides strategic support to both desks, particularly in cross-border transactions involving European structures and assets in Brazil.

The convergence of the energy, maritime, and offshore sectors strengthens the technical capabilities of both practices at a time when the Mercosur–EU and Mercosur–EFTA agreements are increasing regulatory predictability and promoting greater integration of production chains. In an environment of ongoing trade reconfiguration, this coordinated structure enables the firm to advise French and Norwegian investors on adapting to new market access rules, the decarbonization agenda, and the expansion of infrastructure projects in Brazil.