Rodrigo Lazaro is a partner at FCR Law. He handles a broad range of tax matters for national and international companies with a focus on tax litigation, tax planning and restructuring. Rodrigo holds bachelor’s degrees in both Law and Accounting, PhD candidate of Tax Law and hold a LLM program in International Tax Law, two postgraduate diplomas in Business Law (one of them granted by Concordia University – Canada) and one postgraduate diplomas in Tax Law. He also holds a MBA in Tax Management.
Judge at Court of Taxes of the State of São Paulo (Tribunal de Impostos e Taxas), with mandate from 2020 to 2025.

Judging Councilor of the Municipal Tax Council of the municipality of São Paulo (2022/26)

Lecturer and Invited Professor in Graduate and Graduate courses in Law and Accounting Sciences.

Deputy Vice President of Taxes of the National Association of Finance, Administration and Accounting Executives (Anefac).

Lecturer and instructor at the Regional Accounting Council – SP on Tax Law and Tax Planning

Effective member of the Special Commission on Tax Law of the Brazilian Bar Association (OAB-SP) – 2022/2024.

Research member of the research projects “Administrative, Judicial and Tax Enforcement Process of the 21st Century” and “TIT’s Analytical Repertory of Jurisprudence” of the Nucleus of Tax Studies (NEF) of FGV DIREITO SP.

Researcher at IDP’s Fiscal Macrolitigation Observatory (year 2021/22).

Associated with the Brazilian Institute of Tax Law (IBDT) and the National Association of Finance, Administration and Accounting Executives (Anefac).

He was recognized as one of the lawyers referenced by Revista Legal 500 Latin America (2020/21, 2021/22 and 2022/23) and one of the most admired by the magazine Análise 500 (2020 and 2022).

He was appointed Vice-President of the Special Commission on Customs Law and effective member of the Tax Litigation Commission of the Brazilian Bar Association (OAB-SP) – 2019/2021.

He was appointed Integrated Investigator at the Center for Research in Justice and Governance – JusGov (2020/21), in the research line GLOB – Globalization, Democracy and Power (Portugal).

Education Background

PhD in Law, Univ. Coimbra (ongoing) – Portugal
Master in International Taxation, IBDT-USP – Brazil
Continuing education in Business Law, Concordia University – Canada
MBA in Tax Management, Trevisan Business School – Brazil
Post-Graduation in Tax Law, Univ. Presb. Mackenzie – Brazil
Post-Graduation in Business Law, Univ. Presb. Mackenzie – Brazil

Languages

Portuguese
English

Additional Information

BOOKS IN CO-AUTHORSHIP: (i) “ICMS in the Tax and Fees Court of São Paulo” (Fórum, IDP and Abradt Editions) by the article “Nullities in the Tax Notification and Current Precedents of the Tax Court of the State of São Paulo Paulo (TIT-SP)”; (ii) “Current Issues in Tax Law”, published by Editora Lumen Juris, by the article “Tax planning and possible consequences of ADI 2446”; (iii) “Anais – VIII Brazilian Congress of International Tax Law”, by the article “Common Reporting Standard – CRS during the Covid-19 pandemic in Brazil”; (iv) “Administrative, Judicial Proceedings and Tax Enforcement of the 21st Century” and “Administrative, Judicial Proceedings and Tax Enforcement of the 21st Century – Volume II”, both by Ed. Max Limonad in partnership with FGV-SP; (v) “The Current Customs Law”, published by Editora Dialética, with the article “The Digitization of the Economy and its impacts in the Multilateral Policy of Customs Tariffs” and (vi) “Relevant Issues of Customs Law”, by a chapter of the intersection between adjustments in customs valuation and transfer pricing, especially when dealing with the Hamamatsu Case of the Court of Justice of the European Union.

COORDINATED BOOKS: (I) book “Contemporary Customs Law: Issues of Impact on Customs Law and Foreign Trade” by Ed. Dialetica, with Crepaldi and Lostado, and co-author of the article “Exchange of Financial Information for Tax Purposes and its Impacts on Customs Inspection”. (ii) e-Book “Relevant Issues of Customs Law and Foreign Trade” by OAB-SP and author of the articles “Impacts of ADI 4296 in relation to preliminary injunctions in a writ of mandamus in the scope of customs litigation” and “Fraudulent Interposition of Third Parties : contours of its application in the context of current foreign trade”.

ARTICLES IN LEGAL JOURNALS: (i) author of “International Tax Planning Applicable to the Commercial Exploitation of Bitcoins in Brazil”, “Brief Comments on Tax Inversion in Brazil”, “The Automatic Exchange of Banking and Tax Information evolving into a International Custom” and “Taxation on the import of model files for 3D printers”, respectively, in the Current International Tax Law Magazines v. 3, 4, 5 and 8; (ii) Author of the article “Application of anti-abusive rules in treaties against double taxation and tax evasion signed by Brazil after the BEPS and MLI Project” in the Revista de Direito Tributário Contemporâneo, coordinated by Prof. Paulo de Barros Carvalho; (iii) Author of the articles “Controversies on post-BEPS international fiscal policy” and “BEPS 2.0 – brief considerations on the Unified Approach proposed by the OECD”, in the Revista Tributária e Finanças Públicas, respectively, v 137 and v 146.

Rodrigo is associated with the Brazilian Institute of Tax Law (IBDT) and the National Association of Finance, Administration and Accounting Executives (Anefac).