We were hired by a business group in the entertainment and events sector that was looking to integrate business partners into the business. The aim was to expand the group’s operations and develop new products and services.

The operation presented important challenges, such as ensuring that the client’s other businesses were not impacted and preserving existing tax benefits.

In order not to affect the group’s other businesses not included in the business that would be jointly operated by the parties, we drew up an action plan with our client and its partners. We took into account the specifics of their operations, especially previous contracts with their clients and suppliers and the events scheduled during the implementation period of the operation.

Another important challenge of the operation was to preserve the PERSE tax benefit (“Emergency Program for the Resumption of the Events Sector”), established by Law 14.148/2021, which provides for a substantial reduction in federal tax rates such as IRPJ, CSLL and PIS/COFINS for companies belonging to the events sector that meet its requirements.

Our teams specializing in corporate law, contracts and tax law worked together to analyze the case and draw up the necessary documents. After a number of considerations, the decision was made to enter into a partnership agreement and then have the commercial partners join the corporate structure of the business group.

In order not to jeopardize the above-mentioned tax benefit, we developed a strategy in which the company holding the tax benefit merged with another company in the group, and a minority share of the merging company was subsequently acquired by the joining partners, who became partners in the business group.

The configuration developed not only made it possible to maintain the very important tax benefit, but also allowed the partner companies to come together – calmly – and enjoy interesting synergies with each other.