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Humberto Marini

Humberto Marini

He/Him/His
Partner, Campos Mello Advogados (cooperation firm)*
Rio de Janeiro
About

Humberto has an extensive practice in tax consulting and tax litigation, is experienced in the Judicial and Administrative Courts. His work includes responsibility for many substantial cases in state and federal courts, including the Higher Courts in Brazil: Brazilian Taxpayers Council, Superior Tribunal of Justice, and Federal Supreme Court.

He has represented clients in legal transactions with tax authorities regarding tax matters. Humberto has significant experience in VAT/indirect and direct tax matters, as well as in state and municipal taxes, social security, M&A, customs duties, and excise taxes. He has also represented major companies in tax lawsuits, administrative procedures, and consultations at the government tax departments in Brazil.

Among his clients are Brazilian and international companies in industry sectors, such as consumer goods, energy, infrastructure, financial and banking services, mining, hospitality and leisure, retail, industrial goods and services, life sciences and real estate.

He has been assisting Oil & Gas clients for more than 25 years in the tax litigation, representing companies in tax assessments and lawsuits regarding issues related to the industry. He has represented clients in legal transactions with tax authorities regarding tax matters.

DLA Piper and Campos Mello Advogados (CMA) are separate and independent law firms, which work in cooperation with one another. Partners of DLA Piper are not partners of CMA; and CMA partners are not partners of DLA Piper.

Areas of FocusConsumer Goods, Food and RetailEnergy and Natural ResourcesIndustrialsTax
Bar admissionsRio de Janeiro, BrazilSao Paulo, Brazil

EXPERIENCE

  • Assistance to one of the largest manufacturers of water heating products on tax claims involving the State Goods and Services Tax (ICMS). In 2020, our client received nine tax infraction notices claiming that the tax was underpaid, due to entry and remittance transactions with no proper invoicing, and dubious amounts in the inventory, between 2015 and 2019
  • Assistance to a hospitality group with Claims related to a complex Real Estate transaction that is not commonly seen in Brazil. The Municipality of Rio de Janeiro, which is not used to handling similar cases, made several mistakes in relation to the taxation of the transaction, including double taxation
  • Assistance to medical clinic with a tax assessment filed by the Rio de Janeiro tax authorities that disregarded the special treatment determined by the legislation to the companies only composed of determined professionals as doctors. The tax assessment was filed to collect the service tax (ISS) as it was a regular company
  • Assistance to one of the largest producer and supplier of gas in Brazil with the administrative defenses involving the State Goods and Services Tax (ICMS). In 2021, our client received several tax infraction notices claiming that ICMS had not been paid on a transaction performed at the Chamber of Trade of Electric Power (CCEE) and in acquisitions of power from power generation companies
  • Assistance to chemical industry in tax litigation and tax audits regarding their operations
  • Assistance to drilling company in a judicial claim seeking tax exemption and refund. In 2015, our client filed a judicial claim seeking to obtain a decision that the company was not subject to the payment of Tax on Manufactured Products (IPI) and Imported Goods (II). Our client also requested to be refunded for tax amounts unduly paid since the filing of the judicial claim
  • Assistance to leading consumer products industry in a claim issued by the federal tax authorities which disallowed the amortization of the goodwill resulting from the acquisition of companies in Brazil
  • Assistance to world largest tools manufacturer in a judicial claim seeking tax exemption and refund. In 2015, our client filed a judicial claim seeking to obtain a decision that the company was not subject to the payment of Tax on Manufactured Products (IPI) and Imported Goods (II). Our client also requested to be refunded for tax amounts unduly paid since the filing of the judicial claim
  • Represent a Global Maritime Agency on their most important tax litigation in Brazil regarding joint responsibility on importation of products
  • Represent an energy company on a lawsuit to not be subject to the Withholding Income Tax charged by Brazilian Tax Authorities on the remittances abroad for services provided based on tax treaty executed between the Countries where the companies are located
 
Languages
  • English
  • Portuguese
  • Italian
Education

  • Getulio Vargas School of Business, Rio de Janeiro, Tax Specialization, 2003

    Pontifical Catholic University of Rio de Janeiro, B.A., 2001

    B.A., Law, Pontifícia Universidade Católica do Rio de Janeiro, 2001

     

Awards

Chambers Brazil: Regions

  • Band 4, Brazil Tax: Rio de Janeiro (2022 – 2023) 

The Legal 500 Latin America

  • Recommended, Brazil Tax Advisory (2022 – 2024)
  • Recommended, Brazil Tax Litigation (2018 – 2019, 2021)
Additional Recognitions 
  • Best Lawyers, Tax Law in Brazil (2020 – 2023)
  • Recognized by "Análise Advocacia 500" as one of the Most Admired Brazilian Lawyers in Tax (2014 – 2016)

Publications

  • "New Tax Rules for Individuals with Foreign Income" (May 2023)
  • Post - Brazil's Tax Reform (2023)

Seminars

  • Conference with the DLA Amsterdam Tax team, Presentation on initiatives to integrate Tax practice in LATAM and Tax team performance in Brazil (May 2022)
  • Latin America Tax webinar XVI, Focus on US international tax and other global legislation impacting the region (April 2022)

Prior Experience

Before joining Campos Mello Advogados, Humberto worked at several full-service law firms.

Memberships And Affiliations

  • Brazilian Bar Association (OAB), Rio de Janeiro and São Paulo Chapters

My latest insights

News

Campos Mello Advogados advises Carmo Energy in the closing of its acquisition of...

17 January 2023 .3 minute read

News

Campos Mello Advogados advises Starboard in joint acquisition of Pampa Sul power plant in...

27 September 2022 .3 minute read

News

Campos Mello Advogados advises Cobra Group in US$1.1 billion acquisition of Carmópolis...

21 January 2022 .2 minute read

Connect

Phone

+55 21 3262 3000
(Work, Rio de Janeiro)
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