Postgraduate specialization for professionals who wish to acquire advanced knowledge to work in the tax-fiscal area, both in the private sphere (advocacy and legal-fiscal management in companies) and in public advocacy (PGFN, State and Municipal Attorney's Offices).
Course in partnership with IET – Institute of Tax Studies
The specialization provides theoretical and practical knowledge of the area, preparing students for both marketing activities and for entry into master's/doctorate courses. In times of Tax Reform (initiated by Constitutional Amendment No. 132/2023), the National Tax System will undergo significant changes and, therefore, the demand for well-prepared professionals in the tax area will increase significantly in the job market.
The course is aimed at professionals with degrees in Law, Economics, Business Administration, Accounting and related areas.
Held online. Candidates must submit their CV. Places are limited and PUCRS reserves the right to modify and/or extend the application period.
For the purposes of enrollment and preparation of the course completion certificate, the student must present, at the time of enrollment UM of the following documents:
In addition to one of the documents listed above, the student must send the copy of graduation diploma.
General notions of tax law. Nature and function of tax law. Function of doctrine in law. Doctrinal currents: a) normativism; b) legal formalism; c) argumentative constructivism; d. substantial justification; e) fundamental duty. Text and norms. Interpretation. Rules and principles. Normative postulates.
Overview of Brazilian tax law: current issues. Forecasts and perspectives for tax law. Concept of sources of law. Characteristics and functions of sources. Types of sources. Formal sources of tax law: constitutional source; legal source: complementary law, ordinary law, provisional measure, legislative decree; infra-legal source. Interpretative sources. Normative structure. Constitutional reception of the CTN. Constitutional matrix. Conceptualization of article 3 of the CTN. Essential elements of the tax in the 1988 Constitution. Criteria for classification of taxes in the doctrine. Tax types in the National Tax Code. Tax types in the 1988 Constitution: Tax (essential characteristics) and Special Contributions (essential characteristics). Negative Competences: Immunities; Concept; General Notions; Types of immunities. General Theory of Taxes. Compulsory Loan. Improvement Contribution. Extra-fiscality. Formal Limitations: Tax Incidence Matrix Rule; Legality; Legal Reserve; Typicality. Tax Jurisdiction. Types of jurisdictions. Distribution of jurisdictions in the CF/88. Revenue distribution. Legal certainty in tax law. Material limitations: Good faith in tax law; Protection of trust and duties of collaboration; General equality; Tax equality; Tax capacity; Progressivity; Regressivity. Formal limitations: Non-retroactivity and Tax Anteriority. Legal positions and the various legal-tax relationships. Contributory and non-contributory relationships. Tax liability: Modalities; Procedure; Duty of collaboration; Formal original obligation; Normative technique; Illicit as a prerequisite for the obligation of guarantee; Classification: personal, subsidiary, joint and several; Third-party liability. Discrimination of Immunities in the 1988 Constitution. Legal certainty and Protection of Trust.
Legal positions and the various legal-tax relationships. Contributory and non-contributory relationships. Types. Fictions and presumptions in tax law. Tax obligation: primary and accessory obligations; violations of tax legislation. Late payment and ex officio fines. Qualified fines. Isolated fines. Spontaneous reporting. Tax substitution: “forward” substitution; “simultaneous” substitution; backward substitution. Withholding. Misappropriation of funds. Substitute liability. Types of tax liability. Procedure for recognizing and enforcing tax liability. Duty to collaborate. Formal original obligation. Normative technique. Illicit act as a prerequisite for the obligation of guarantee. Classification: personal, subsidiary, joint and several. Third-party liability. Qualification of economic groups in tax law.
Formalization of tax credits through acts of the taxpayer: declarations, debt confessions, payment and deposit slips. Formalization in labor claims. Extinction of tax credits. Hypotheses of article 156 of the CTN. Expiry and prescription. Tax dynamics and deadlines. Expiry deadlines according to the type of assessment. Expiry in light of the taxpayer's declarations. Credit fragmentation. Simultaneous course of expiration and prescriptive deadlines. Peremption in the course of the tax administrative process. The term a quo of the prescriptive deadline. Challenges and partial appeals. Suspensions and interruptions of the prescription. Intercurrent prescription. Suspension of the enforceability of tax credits. The various types of installment payments. Challenges and administrative appeals. The manifestation of non-compliance and other administrative defenses. Injunctions against the Public Treasury. Effects of the suspension of enforceability. Tax exemption: exemption, zero rate, amnesty and remission. Incidence and exemption. Theories on the phenomenon of exemption. Tax compensation. General rules and specific legislation. Ex officio compensation and under the system of assessment by approval. Undeclared compensation. Disputes related to compensation. Effects of compensation. Payment. Tax undue payment. Legitimacy for recovery. Taxpayer by law and in fact. Economic repercussions. Guarantees and privileges of tax credit. Credit in bankruptcy. Tax administration. Inspection. Tax authorities' prerogatives. Tax secrecy. Active debt. Certificates of Tax Compliance. Alternative Methods for Resolving Tax Disputes.
Research and preparation of scientific papers. Research in tax law.
Federal Taxes: Fundamentals of Income Tax. IRPJ and CSLL. Tax planning involving income taxation. Off-shore structures and taxation in Brazil. ICMS: Rule of constitutional jurisdiction and general notions. Legislation of the state of Rio Grande do Sul and interstate transactions. ISSQN and ITBI: rule of constitutional jurisdiction; complementary law; concept of service. Taxation on foreign trade: customs law; II, IE, PIS/Cofins-import and ICMS-Import. IPI. ITCMD. IPTU. ITR. Contributions on income (social security and third parties). Contributions on revenue (cumulative and non-cumulative PIS/Cofins). Tax neutrality. Taxation of companies that develop activities in accordance with the rules of Simples Nacional.
Taxation of agribusiness. Rural producer as an individual. Rural producer as a legal entity. Agro-industries. Income tax, contributions on revenue, social security contributions, tax on rural land and tax on the circulation of goods related to rural producers and agro-industries. Taxation of the financial and capital markets. Taxation of the third sector.
Globalization and new challenges in the taxation of international trade. The role of the taxpayer in international trade relations. Tax jurisdiction and interstate relations. The issue of establishments in international tax law. Transfer pricing. Taxation in the context of international economic relations on income and companies. International treaties on tax matters and the issue of double taxation. Dispute resolution in the context of international tax law.
Fundamental Elements of Recording Accounting Facts: Recognition, Classification and Measurement. Financial Statements. Evolution of Accounting. Accounting Law. Sources of Accounting Standards. Conceptual Framework for Preparation and Presentation of Financial Statements. Fundamental Elements of Recording Accounting Facts: Overview. Relationship between Tax Law and Accounting. IFRS. Applied Tax Accounting.
Fundamental Duty to Pay Taxes. Fundamental Right of Tax Economics. Tax Planning from a Tax Perspective. Concept of Business Purpose. Analysis of CARF case law involving tax planning. Judicial Case Law on Tax Planning. Tax Planning and Complex Legal Structures.
Compliance and corporate governance: Shareholders e Stakeholders. Tax Compliance from the Taxpayers' Perspective. Tax Compliance from the Tax Authorities' Perspective. Cooperative Compliance and the Ethics of Self-Restraint. “Best Practices” and the Implementation of a Corporate Tax Compliance Program. Government Tax Compliance Programs. Tax Compliance and Tax Reform. Violations of Tax Regulations from a Criminal Perspective. Criminal Offenses. Sanctions. Crimes Against the Tax Order. Tax Criminal Procedure.
Tax action. Federal, state and municipal tax administrative proceedings. Principles in procedural matters. Instrumentality. Contradictory and full defense. Litigation phase. Administrative judgment bodies. Parity. In dubio pro taxpayer. Consultation. Customs inspection. Writ of mandamus in tax matters. Declaratory, annulment, recovery of undue payment and consignation actions. Fiscal precautionary measure, tax enforcement, pre-enforcement exception and embargoes to enforcement. Deposit of the full amount. Provisional relief. Constitutional jurisdiction. The relationship between the STJ and STF in the exercise of constitutionality control and its impact on tax law. Types of constitutionality controls. Diffuse means. Constitutional actions for direct constitutionality control. Binding precedents. The system of general repercussion. Implications of STJ and STF decisions on tax disputes. Res judicata in the constitutional tax process. Analysis of theses defined by the STJ and STF.
Introduction to Tax Reform and its Foundations: Constitutional Amendment No. 132 and Complementary Law No. 214: objectives and impacts. The process of replacing ICMS and ISS with IBS and CBS. The new tax model and its simplification. The concept and function of the Selective Tax. The Tax on Goods and Services (IBS): Characteristics and functions of the IBS. The impact of the transition from ICMS and ISS to IBS. IBS jurisdiction and collection rules. Calculation and incidence of IBS: domestic and interstate transactions. The interaction of IBS with foreign trade transactions. The Contribution on Goods and Services (CBS): Distinctions between CBS and IBS. Characteristics of CBS: calculation, incidence and scope. CBS in the context of the unification of consumption taxes. The adaptation of companies to the new taxation model. Selective Tax: Analysis of the concept, function and application of the Selective Tax. Types of goods and services subject to the Selective Tax. Attributes and regulation of the Selective Tax. Tax implications for companies and consumers. Tax Jurisdiction and Revenue Sharing: The redistribution of powers among the federative entities. Revenue sharing and its impacts on states and municipalities. The strengthening of taxation at the federal level and its tax implications. Impacts for Companies and Taxpayers: Implications of tax reform on corporate tax planning. The impact of the new rules for assessment and collection on the private sector. Tax compliance in the new model: accessory obligations and inspection processes. The treatment of interstate and international transactions in the new system. Practical Aspects of the Transition to the New Model: The adaptation of companies and taxpayers to the new tax rules. The transition regime between the old and the new system. Challenges and opportunities for tax and fiscal compliance. Analysis of Future Reform Proposals and their Impacts: Future trends in tax reform. The role of the Selective Tax in future reforms. The possibility of new adjustments in tax legislation in response to the implementation of the reform.
The TCC may be completed within a maximum period of 6 months after completing the courses. The guidance schedules will be defined by each Academic Unit.
Prof. Dr. Claudio Lopes Preza Junior
Email: claudio.preza@pucrs.br
Lawyer registered with the OAB/RS. Master's student in Political and Economic Law at Universidade Presbiteriana Mackenzie. Master's degree in Political Science from Universidade Federal do Rio Grande do Sul (2003). PhD in History of Law from PUCRS (2024). Graduated in Law in 1997 from the Pontifical Catholic University of Rio Grande do Sul. Member of the Internationalization Support Group of the Graduate Program in Law and Political and Economic Law at Universidade Presbiteriana Mackenzie – SP. He is currently an assistant professor at Pontifical Catholic University of Rio Grande do Sul. He teaches Tax Law I, Tax Law II and Tax Practice. He has experience in Political Science and Tax Law. Coordinator of the Specialization Course in Tax Law PUCRS Online and Coordinator of the Specialization Course in Tax Law PUCRS in-person modality and professor of these same courses. Coordinator of the Undergraduate Tax Law Study Group at PUCRS Law School and Coordinator of the PUCRS TAX TEAM.
Danielle Bertagnolli
Email: danielle@bertagnolli.adv.br
Lawyer registered with the OAB/RS. Specialist in Tax Law from the Brazilian Institute of Tax Studies (2013). Bachelor in Legal and Social Sciences from the University of Passo Fundo (2011). Visiting professor at the Brazilian Faculty of Taxation since 2019. Researcher linked to the Institutional Research Group on Tax Justice and Gender at the State University of Rio de Janeiro. Associated with the Institute of Tax Studies (IET) and the Brazilian Institute of Tax Law (IBDT).
| Public | Price |
|---|---|
| general public |
Registration fee of R$ 1.100,00 + 18 installments of R$ 1.100,00
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| Groups of 5 to 9 people |
Registration fee of R$ 1.100,00 + 18 installments of R$ 1.045,00
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| Groups of 10 to 19 people |
Registration fee of R$ 1.100,00 + 18 installments of R$ 1.017,50
|
| Group of 20 or more people |
Registration fee of R$ 1.100,00 + 18 installments of R$ 990,00
|
| Students aged 60 and over |
Registration fee of R$ 1.100,00 + 18 installments of R$ 880,00
|
| Public | Price |
|---|---|
| PUCRS Alumni |
Registration fee of R$ 1.100,00 + 18 installments of R$ 968,00
|
| Teachers and Administrative Technicians of the Marist Network |
Registration fee of R$ 1.100,00 + 18 installments of R$ 880,00
|
| Employees of Tecnopuc Companies |
Registration fee of R$ 1.100,00 + 18 installments of R$ 880,00
|
| PUCRS, HSL, InsCer, Clinical Center and Fijo employees |
Registration fee of R$ 1.100,00 + 18 installments of R$ 550,00
|
| Public | Price |
|---|---|
| Partner Companies* |
Registration fee of R$ 1.100,00 + 18 installments of R$ 990,00
|
| Civil servants of RS and their dependents (spouse, partner, ascendants and descendants up to the second degree) |
Registration fee of R$ 1.100,00 + 18 installments of R$ 880,00
|
| Employees of the Federal Savings Bank |
Registration fee of R$ 1.100,00 + 18 installments of R$ 880,00
|
From 16/5/2025 to 8/6/2025 – 30% discount - R$770,00
From 9/6/2025 to 29/6/2025 – 20% discount - R$880,00
From 30/6/2025 to 20/7/2025 – 15% discount - R$935,00
From 21/7/2025 to 27/7/2025 – 10% discount - R$990,00
The amounts above refer to course registration, the remaining installments are due from the start of the course.
The registration fee must be paid on the date of registration. The differentiated amount for the other installments is granted starting from the first monthly payment of the course. The monthly payments will begin after the beginning of the course, with due date on the 15th of each month, via bank slip.
In the case of cash payment, the student will be granted a 10% discount on the value of all installments.
Requests for a discount for advance payment of the course must be made via email to financeiro@pucrs.br.
After the request, you will be informed of the amount to be paid, bank details for credit, as well as the deadline for advance payment with the respective discount.
If the course is cancelled, the calculation of refund amounts for overdue installments will disregard the discount granted since the registration was paid.
Educational credit allows financing of 50% of the course installments, with a repayment period equivalent to the number of installments used.
For more information or questions, please contact the financial department: creditos@pucrs.br.
Support from PUCRS Carreiras, with training and solid consultancy and advisory work.
Qualified teachers and updated programs for your professional development.
Every year we offer hundreds of internship opportunities and we are a bridge between students and major companies in the market.
Multiple facilities for hands-on activities that enhance classroom learning and equip students for real-world professional challenges.
The event brought together more than 200 participants from 34 countries and positions the university as a global reference in public innovation and digital transformation
Tuesday, June 17 | 2025
