ENERGY TALKS

Edgar Santos Gomes

edgar.gomes@tagdlaw.com.br

Education

Law Degree from Universidade Federal do Rio de Janeiro – UFRJ (2004). Specialization in tax law at the Brazilian Institute of Tax Studies – IBET (2006). Master of Laws (LL.M.) in International Tax Law at the University of Leiden, Netherlands (2010).

Visiting professor of international tax law and lecturer in universities in Brazil and abroad.

15 years of experience in administrative and judicial tax litigation; tax consulting and planning, in domestic and international transactions involving individuals and companies resident in Brazil and abroad.

Associations

Brazilian Bar Association in Rio de Janeiro (2005); Brazilian Bar Association in São Paulo (2011); International Fiscal Association (2013); Brazilian Association of Financial Law (2013); and the Society of Trust and Estate Practitioners (2019).

Member of the Commission on Asset Recovery in International Fraud of the Brazilian Bar Association of the State of Rio de Janeiro (OAB/RJ) and the Tax Reform Commission of the State of Rio de Janeiro in the working group on estate taxation.

Languages

Portuguese | English | Spanish

Publications

  • Co-author of “Tax Challenges of Digital Inheritance.” Published in International Tax Law in Practice: From the Basics to the New Rules, 1st ed. São Paulo: MP Editora, 2025. APET Continuing Education Series.
  • Co-author of “Key Aspects in the Taxation of Dividends, Interest, and Interest on Net Equity (JCP).” Published in International Tax Law in Practice: From the Basics to the New Rules, 1st ed. São Paulo: MP Editora, 2025. APET Continuing Education Series.
  • Author of “Withholding Income Tax on Payments to Foreign Service Providers: An Analysis of Articles 3.2, 7.1, and 21 of the Tax Treaties and the Broadening of the Concept of Technical Services by the Brazilian Federal Revenue.” Published in TAGD Advogados 10 Years: Legal and Business Perspectives. Rio de Janeiro: Lumen Juris, 2024.
  • Co-author of “Accounting and Taxation of Tax Assets – Individual Lawsuits Involving Tax Recovery in the Presence of Binding Judicial Decisions.” Published in IFRS, Accounting, and Taxation – Volume 2 – Tribute to Elidie Palma Bifano. São Paulo: Quartier Latin, 2024.
  • Co-author of “The Taxation of Redeemable Life Insurance Policies.” Published in New Taxation of Offshore and Investment Funds – Theory and Practice of Law 14.754/23 – Vol. 1. São Paulo: Quartier Latin, 2024.
  • Co-author of “Brazil’s New Transfer Pricing Rules.” Published in TAGD Advogados 10 Years: Legal and Business Perspectives. Rio de Janeiro: Lumen Juris, 2024.
  • Co-author of “Transfer Pricing and Dispute Resolution: Administrative Approaches and Mutual Agreement Procedures.” Published in Transfer Pricing in Brazil: Towards Convergence with the OECD Standard. São Paulo: Quartier Latin, 2023.
  • Co-author of “Estate Planning and the Brazilian Supreme Court Ruling on Non-Incidence of Income Tax.” Portal JOTA. August 2023.
  • Co-author of “The Broadening of the Concept of Technical Services by the Brazilian Federal Revenue: Withholding Tax, Double Taxation Treaties, and the Vienna Convention.” Published in Studies in International Taxation – Volume 3. Editors: Daniel Cordeiro, Edgar Santos Gomes, Flávia Cavalcanti, Gustavo Godoy. Rio de Janeiro: Lumen Juris, 2019.
  • Co-author of “The Non-Discrimination Principle in Tax Treaties and Its Applicability.” Published in Studies in International Taxation – Volume 2. Editors: Ana Paula Saunders, Maurício Terciotti, Michel Batista, Janssen Murayama. Rio de Janeiro: Lumen Juris, 2018.
  • Co-author of “The Definition of Tax Residence in Brazil and the Issue of Dual Residence: Overlooked Double Taxation Scenarios.” Published in Studies in International Taxation: Base Erosion and Profit Shifting – Concepts and Case Studies. Editors: Edgar Santos Gomes, Francisco Lisboa Moreira, Marcus Lívio Gomes. Rio de Janeiro: Gramma, 2018.
  • Co-author of “Transfer Pricing in the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting.” Published in Transfer Pricing Handbook – Volume II. São Paulo: Quartier Latin, 2018.
  • Author of “Tax Transparency and Disclosure in Brazil.” Published in Bulletin for International Taxation – Volume 71 – Number 6 – 2017. IFA 71st Congress Special Issue. IBFD, 2017.
  • Co-author of “Article 1 of the OECD Model Convention and the Role of Tax Treaties in Brazil.” Published in Studies in International Taxation. Editors: Ana Paula Saunders, Edgar Santos Gomes, Francisco Lisboa Moreira, Janssen Murayama. Rio de Janeiro: Lumen Juris, 2016.
  • Co-author of “OECD BEPS Action Plan 4 – Limits on Base Erosion via Interest Deductions and Other Financial Payments.” Published in International Taxation in the Post-BEPS Era. Rio de Janeiro: Lumen Juris, 2016.
  • Co-author of “Methods to Avoid Double Taxation and Related Controversies.” Published in International Tax Law – In Honor of Professor Alberto Xavier. São Paulo: Quartier Latin, 2016.
  • Co-author of “Quick Guide to Brazil’s Asset Repatriation Law.” Portal JOTA. January 2016.
  • Author of “Alternatives to Ensure the Reasonable Duration of the Tax Administrative Process.” Published in XXIX Latin American Conference on Tax Law. Santa Cruz de la Sierra, Bolivia. November 2016.
  • Co-author of “BEPS – Final Reports Approved. What Now?” Portal JOTA. January 2016.
  • Author of “The Pavarotti Case: Taxation of Foreign Income Earned by an Artist with Dual Tax Residence – The Concept of Tax Residence and the Application of Article 4 of the OECD Model Convention.” Published in International Taxation: Case Studies – Volume 3. Coordinator: Leonardo Freitas de Moraes e Castro. São Paulo: MP Editora, 2015.
  • Co-author of “Opinion PGFN/CAT No. 2.363 and Payments Abroad for Services Without Technology Transfer.” Published in ABDF Electronic Journal 33. April 2014.
  • Author of “State Taxation of the Oil Sector is a Self-Defeating Move.” Published in Valor Econômico. September 2014.
  • Co-author of “Taxation of Profits from Controlled and Affiliated Companies Abroad According to New STF Ruling – Taxation Before Profit Distribution in Tax Havens – Is the Distinction Valid?” Published in ABDF Electronic Journal 24. April 2013.