Lyvia Serpa has over 15 years of experience in tax law, with a focus on both consulting and litigation. Her practice includes technical interaction with tax authorities, assistance in tax audits, preparation of legal opinions, oral advocacy before administrative and judicial bodies, and coordination of team-based work, combining substantive and procedural aspects of tax law.

Lyvia holds a PhD in Law from UERJ and has relevant academic publications, as well as experience as a speaker at professional and academic events, contributing to a solid and up-to-date perspective on the impacts of the Tax Reform and other key tax matters.

Education

• PhD in Law, Rio de Janeiro State University (UERJ), with a focus on Public Finance, Taxation, and Development. Supervisor: Sérgio André Rocha (2023).

• Master’s Degree in Law, Rio de Janeiro State University (UERJ), with a focus on Public Finance, Taxation, and Development. Supervisor: Luís Cesar Souza de Queiroz (2016).

• Postgraduate Certificate (lato sensu) in Financial and Tax Law, Fluminense Federal University (UFF) (2009).

• Bachelor of Laws (LL.B.), Fluminense Federal University (UFF) (2007).

Languages

• Portuguese and English

Experience

• Strategic tax advisor in high-profile matters, including the following key cases:

• Tax advisory and risk assessment services in connection with an investment of BRL 601 million in a leading company in tire solutions through a foreign fund.

• Risk assessments related to acquisitions led by a market-leading company in the comprehensive kidney care provider sector.

• Judicial litigation involving approximately BRL 90 million concerning the assessment of State VAT (ICMS-DIFAL) against a retail company specializing in sporting goods.

• Judicial litigation involving approximately BRL 80 million concerning the collection of Export Tax on crude oil.

• Judicial litigation involving approximately BRL 75 million concerning goodwill amortization.

• Judicial litigation concerning assessment and collection of State VAT (ICMS) in the approximate amount of BRL 70 million against a catering company.

• Judicial litigation concerning the payment to the Temporary Budgetary Fund (FOT), corresponding to a 10% rate, calculated on the difference between the amount of tax assessed with and without the application of tax benefit granted to automobile manufacturers in the State of Rio de Janeiro.

• Judicial litigation involving approximately BRL 50 million concerning the refund (recovery) of unduly paid State VAT (ICMS) on the importation of goods used in the oil and gas industry.

• Judicial litigation involving approximately BRL 25 million concerning claims arising from Supreme Federal Court binding precedent no. 69.

• Judicial and administrative litigation involving approximately BRL 100 million concerning claims related to tax immunity of a higher education institution in the State of Rio de Janeiro.

• Administrative litigation involving approximately BRL 1.3 billion concerning the assessment of federal social contribution taxes (PIS and COFINS) against a telecommunications company.

Articles & Publications

• “Topic 1273/STJ: The End of the Writ of Mandamus in Tax Matters?” Article published on the JOTA Portal on September 1, 2025.

• “Tax Principles Set Forth in Article 145, Paragraph 3, of the Brazilian Federal Constitution.” In: Female Voices in the Tax Reform. (2024).

• “Recent Developments on the Non-Incidence of ICMS on Transfers Between Establishments of the Same Taxpayer: ADC 49, ICMS Agreement No. 178/2023 and Supplementary Bill No. 116/2023.” In: ICMS and Agribusiness – Book in Honor of Professor Fábio Calcini. (2024).

• “Ricardo Lobo Torres’ Contributions to the ICMS Taxable Event.” In: Financial and Tax Law in the Works of Ricardo Lobo Torres. (2020).

• “The Brazilian Supreme Federal Court and the Concept of Taxable Services for ISSQN Purposes.” In: Tax Law Topics in Honor of Gilberto de Ulhôa Canto. (2020).

• “Jurisdictional Conflicts Between States and Municipalities and Transactions Involving the Transfer and/or Licensing for Use of Software.” In: Taxation of the Digital Economy. (2019).

• Tax Cooperation in Tax Law: a Model for Preventing Disputes Between Tax Authorities and Taxpayers. (2017).

• Exemption from ICMS tax collection arising from an incentive not approved by CONFAZ versus the taxpayer’s legal certainty. In: Taxation & Telecommunications. (2016).

• “The impacts of taxation in the oil and gas sector on the competitiveness of local suppliers in comparison with foreign suppliers.” In: Taxation in the Oil and Natural Gas Industry ( 2016).