Marcio Zanon

Global Tax Executive with extensive experience in Transfer Pricing, M&A structuring, and Direct & Indirect Tax Planning. Trusted business partner to C-level executives, combining governance, compliance, and strategic vision to create sustainable value. Collaborative leader with a proven record in free trade zones (ZFM/SUDENE) and cross-border tax strategies. Technical & Detailed (for Role/Experience section) • Expertise in Free Trade Zones (ZFM/SUDENE) and tax incentives, maximizing operational and financial efficiency. • Leadership in Transfer Pricing and Global Tax Planning, aligned with OECD standards and complex cross-border structures. • Solid experience in M&A goodwill (ágio), deal structuring, and risk assessment. • Proven ability in Direct & Indirect Tax Planning, balancing compliance, risk management, and business value. • Development of governance and tax compliance frameworks that are preventive, integrated, and audit-ready. • Strategic collaboration with Operations, Production, Marketing, and Sales to position tax as a competitive advantage. • Recognized for a business partner mindset and collaborative, proactive leadership, enabling sustainable decision-making. • Advocate of an integrated and preventive tax model that ensures predictability, legal certainty, and competitive edge.

Designed and implemented global tax governance focusing on risk management, TP compliance, and APA/MAP strategies. • Led quarterly tax risk assessments and SOX reporting to internal and external stakeholders. • Contributed to ETR management by aligning with regional/local tax leaders on audits and litigation. • Provided strategic guidance on tax proceedings and proactive risk mitigation. • Developed new TP models and supported global and local finance teams. • Ensured full compliance with OECD requirements (Master File, Local File, CbCR, DAC6). • Monitored OECD, EU, UN, and local developments to assess impacts on tax policy and planning. • Partnered with Finance, Tax Accounting, ESG, Investor Relations, Operational TP, and Treasury teams.

• Tax Finance: Management of Tax Strategy with focus on P&L & Cash Tax gains bringing savings of USD 80 million. • Tax Consulting: Responsible to drive best solutions to provide Tax-oriented advice to stakeholders. • M&A: Leader of all Tax due diligence fronts in order to optimize M&A opportunities bringing tax results of USD 200 million in offsetting strategies. • Tax Risk Expert: Implemented KPI tools capable to identifying & managing relevant grey zones that may cause Financial & Reputational Risks avoiding potential threats around USD 30 million. • Tax Planning: Implemented Tax scenarios that drove Senior Management with several Tax Planning projects attained to business needs bringing Tax savings around USD 140 million. • Tax Tech: Implementation of SSC, partner with IT team to ensure the Technology roadmap was executed in the Brazilian SSC as well as help drive Innovation Projects. • Tax Controller: Control & Review of tax fillings for internal & external audits. • Tax Reporting: Lead & coordinate external Tax Reports & Income Tax forecast & provisions (ETR). • Gov. Affairs: Participate actively on Government & Private associations anticipating any surprises. • Tax Controversy: Management of administrative & judicial Tax Assessments. • Tax Customs: Coordinate & Lead any Custom Tax Projects regimes with ROE Tax impacts. • Transfer Pricing & International Taxes: Coordinate with the Global Transfer Pricing and Global Tax Dispute Groups on documentation, Tax trainings, Tax audits & litigations and advance pricing agreements. • BR GAAP & US GAAP: Advise the Tax Leadership team on all relevant Tax and Tax accounting issues impacting the Brazilian companies. • People: Lead staff development processes, including succession planning and performance calibration. • Project Management: Leader of Tax Corporate Projects and broad-based Technical Tax knowledge, with expertise in US GAAP Tax accounting, Tax compliance and Tax transformation fronts.

Senior Tax Manager / Tax Director Report to: CFO - Brazil. Responsibilities: Direct Taxes, Transfer Pricing, Planning, System Compliance, and Customs. * Direct & Indirect Taxes; Strategic Planning for ICMS benefits vs. logistics; Provide Tax advice and support to businesses across Brazil. * Inquiry in the legislation and provide update to the local Tax Compliance team and to the various Samsung businesses. * Liaise with the local Tax Compliance team to provide the necessary Tax support, appropriate invoice methodology and coordinating with IT Development teams to implement robust taxing and reporting processes. Provide support to the IT Development teams. * Support Legal; Tax incentives leader for Exploitation Profit, R&D Technological Innovation, Rouanet Law, TP (Planning & Litigious). * Ad Hoc: Tax Litigation - litigation involving all taxes (Judicial and Administrative Courts); Consulting on general taxes for domestic companies. Review and drafting of contracts (corporate).

Provided strategic tax leadership across business units, aligning tax planning with Amazon’s global operational and financial objectives. • Built and managed strong cross-functional relationships with senior stakeholders, while mentoring and developing junior tax professionals. • Ensured full compliance with Brazilian and international tax regulations, leveraging deep technical expertise to mitigate risks and identify opportunities. • Designed and evaluated complex tax models and planning scenarios, supporting business decisions through data-driven analysis. • Acted as the primary interface with tax authorities, leading audits, managing tax assessments, and ensuring robust defense strategies in controversial matters.

Novo modelo de Preços de Transferência OCDE no Brasil

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