Antonio Lopo Martínez

From

Brazilian Federal Revenue Service, Ministry of Finance - BR

& Faculty of Law, University of Coimbra - PT

In residence at

Institute of Interdisciplinary Law Research (IRJI) / University of Tours - FR 

Host scientist

Fabienne Labelle

BIOGRAPHY

Antonio Lopo Martínez is a Federal Tax Auditor at the Brazilian Federal Revenue Service and a collaborating researcher at the University of Coimbra Institute for Legal Research (UCILeR). His academic background includes PhDs in Law from the Universities of Coimbra and Salamanca, a PhD in Accounting from the University of São Paulo, and a Master’s degree in Business Administration, with a focus on Accounting, from the University of California, Berkeley. His interdisciplinary research focuses on international and comparative tax law, wealth and succession taxation, tax transparency, digital assets, tax accounting and investment law. At LE STUDIUM, he examines patrimonial structures and digital tax governance in France and Brazil.

PROJECT

Patrimonial Structures and Digital Tax Governance in France and Brazil: High‑Net‑Worth Wealth, Transparency, and Crypto‑Assets as a Stress‑Test Case

Digital tax governance is fundamentally transforming how wealthy families manage and transmit their assets across generations. Through international data exchange agreements, beneficial ownership registers, and automated reporting systems, tax authorities now possess unprecedented visibility into the patrimonial structures that high-net-worth individuals have long used for succession planning and asset protection. In both France and Brazil, traditional vehicles such as family holding companies, civil patrimonial companies, and professional practice entities must now operate under conditions of full transparency that were unimaginable just a decade ago. This regulatory shift demands a fresh examination of how these structures function, evolve, and adapt to new compliance requirements while continuing to serve legitimate family governance objectives.
Within this shifting landscape, crypto-assets offer a particularly revealing stress-test for traditional patrimonial structures. Their borderless nature allows transfers across jurisdictions with minimal friction; their technical complexity raises novel questions about proof of ownership and secure access via private keys; and their rapidly evolving regulatory treatment creates uncertainty for practitioners and families alike. When wealthy families seek to incorporate digital assets into their succession planning, these characteristics expose precisely where conventional legal tools reach their limits and where doctrinal and practical innovation becomes necessary.
This Franco-Brazilian comparative research project, hosted at the University of Tours, brings together academic expertise in patrimonial and succession law with decades of practical experience in tax enforcement and compliance. The collaboration will produce scholarly publications for leading law reviews, policy recommendations for practitioners and tax authorities, and teaching materials for graduate students, while establishing a lasting institutional partnership between French and Brazilian research communities.