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Marcelo Gustavo Silva Siqueira

He/HisSenior Associate

Marcelo Siqueira assists Brazilian and foreign legal entities and individuals in tax consulting and planning issues, with a focus on direct and cross-border taxes.

DLA Piper and Campos Mello Advogados (CMA) are separate and independent law firms, which work in cooperation with one another. Partners of DLA Piper are not partners of CMA; and CMA partners are not partners of DLA Piper.

Bar admissionsRio de Janeiro, Brazil


  • Tax planning and consultancy for Brazilian investment in Africa and a construction agreement worth R$200 million
  • Tax planning and consultancy for the reorganization of a group which creates and sells books and teaching methods for its activities in Brazil and abroad
  • Consultancy regarding cost sharing agreements
  • Consultancy of the tax aspects of service render agreements by a Brazilian company with a public one worth billions of Brazilian reais per year
  • Consultancy of a loan or guarantee to be provided by a Brazilian company in the amount of US$200 million to a foreign group company
  • Tax planning regarding the licensing of Brazilian trademarks between parties in Brazil, US and UK
  • Consultancy regarding the taxation of intragroup loans amounting R$50 million and the alternatives to solve this issue without the transfer of cash between the group companies
  • Consultancy regarding the taxation of the agreement to supply electric modules worth R$200 million to FPSOs
  • Tax planning and consultancy of a transaction worth US$60 million regarding the Rio 2016 Olympic games
  • Tax planning for the sale of a real estate property for R$350 million by a Brazilian company controlled by a foreign individual
  • Consultancy regarding the taxation of a non-resident in Brazil in a direct or via debentures loan,  convertible in shares, worth R$40 million and its further paying in in an investment fund where he is quotaholder
  • Consultancies regarding the taxation and regularization of assets and income held abroad by residents in Brazil (always regarding significant amounts)
  • Portuguese
  • English
  • Universidade do Estado do Rio de Janeiro, Master’s Degree in International Law, 2012, cum laude

    Instituto Brasileiro de Direito Tributário, Postgraduate Qualification in Tax Law, 2008

    IBMEC, LL.M. in Corporate Law and Capital Markets Law, 2005

    Pontifícia Universidade Católica do Rio de Janeiro, B.A. in Law, 2002
  • Post-Graduate Degree, Tax Law, Instituto Brasileiro de Direito Tributário 2008
    Lato sensu
  • LL.M., Corporate and Capital Markets Law, IBMEC 2005

Pro Bono

Assisted NPOs, including the Nature Conservancy and the Global Food Banking Network, in tax matters


  • Honorable Mention, "Investimento Brasileiro no Exterior: Desafios pela Tributação Imediata de Lucros do Exterior e a Falta de Acordos de Investimentos (Bits)," In: Rio Oil & Gas 2014 – Expo and Conference, 2014
  • Author, "Investimentos estrangeiros e inovação tecnológica," In: SÁ RIBEIRO, Marilda Rosado de (org) Direito Internacional dos Investimentos, Renovar, 2014


  • Presentation of paper, "Investimento Brasileiro no Exterior: Desafios pela Tributação Imediata de Lucros do Exterior e a Falta de Acordos de Investimentos (Bits)," Rio Oil & Gas 2014 – Expo and Conference, Rio de Janeiro, Brazil, 2014

Memberships And Affiliations

  • Instituto dos Advogados Brasileiros (IAB)
  • Associação Brasileira de Direito Financeiro (ABDF)
  • International Fiscal Association (IFA)