Livia Heringer

Of Counsel in the Tax Department


Livia Heringer is specialized in tax law and procedural tax law, with significant experience in administrative and judicial tax litigation involving complex and strategic cases of national and foreign companies.

She engages in further activities in the coordination of works of tax proceeding reviewing to identify potential tax credits and to indicate risks and contingencies.

Mrs. Heringer participated in proceedings involving merger and acquisitions of large-sized companies, legal and tax audits, and in major biddings promoted by the public authorities.

She has previous experience in the sectors of chemical and cosmetic industry, retail trade, pharmaceutics, services, and infrastructure.

Representative Cases

  • Strong practice experience in the Superior Courts and in Local Courts throughout the country, as well as in Administrative Courts at the federal, state and municipal levels
  • Experience in managing portfolios of tax cases, with emphasis on a portfolio of more than R$ 1 billion of a large multinational chemical industry
  • Filling of defenses in tax notices and tax foreclosures or annulment actions against the collection of taxes or social security contributions; as well as lawsuits to present a guarantee prior to the tax foreclosure, in order to enable the issuance of clearance certificate and prevent the protest of overdue liabilities certificate (CDA), the registration of the taxpayer in the default registration (Cadin) and credit analysis firms (SERASA)
  • Filling of writ of mandamus against undue taxes levied by the tax authorities (tax thesis), including for the release of seized goods
  • Drafting of legal opinions regarding tax and tax procedural law matters, offsetting proceedings and the taxation of credits recognized by the Courts
  • Filling of defenses against the denial of offsetting proceedings by the Federal tax authorities;
  • Advising on the use of tax credits arising from undue or overpaid taxes, or from a final and unappealable court decision
  • Filling of consultancies regarding the interpretation of the tax legislation or the tax classification of goods
  • Advising how to subscript to amnesty programs;
  • Assistance in enrollment in special regimes, bringing to the Judiciary illegitimate obstacles brought by tax authorities


Master’s degree in Tax Law, University of Sao Paulo, Brazil, 2020

Summer Course in International Tax Law coordinated and co-taught by Prof. Dr. Kees van Raad – First week (Tax treaties) and Second week (Advanced subjects), International Tax Center Leiden, Leiden University, Netherlands, 2015

Specialist in Accounting, Controllership, and Finances, Fundação Instituto de Pesquisas Contábeis, Atuariais e Financeiras – FIPECAFI, Brazil, 2014

Specialist in Tax Law, University of Sao Paulo, Brazil (2012)

J.D., University of Sao Paulo, Brazil, 2008


Mrs. Heringer is a native Portuguese speaker and fluent in English.