The alleged tax fraud schemes involving the Fast Shop and Ultrafarma retail chains over the past four years appear to have operated, according to initial findings, through the exchange of simple files attached to emails between tax auditors and the companies. Requests for assistance from front-line executives to the alleged ringleader, tax auditor Artur da Silva Neto, were reportedly answered quickly—often in just a few words or short paragraphs—when it came to instructions from the public official, Valor has learned.
The database under review by the São Paulo State Prosecutor’s Office contains at least 174 emails exchanged in 2024 between Mr. Silva Neto and Ultrafarma staff, and another 200 emails between the auditor and Fast Shop’s board, totaling nearly 400 messages. “They are basically orders, instructions—it’s all very clear in the messages and hard to deny,” said a source familiar with the case. Fast Shop said it has not had access to the investigation but is cooperating with authorities. Ultrafarma did not comment.
Email attachments titled “Alignment with Artur,” sent from Fast Shop’s executive board to Mr. Silva Neto, were found, as well as other files labeled with codes and numerical references such as “Cat 42” or “txt Cat42.” These are among the materials under investigation for suspected irregular requests and approvals of ICMS credit refunds for the electronics retailer. The retailers allegedly paid bribes to officials to “jump the line” for reimbursement of Tax on Circulation of Goods and Services (ICMS).
According to sources, defense attorneys have offered the Prosecutor’s Office the cooperation of one of the suspects to provide further details.
Operation Ícaro, which investigated the case, seized about R$1.8 million in cash, R$10 million in cryptocurrencies, and two sacks of emeralds—whose value is still being assessed—during search and seizure warrants at the homes of tax auditors and Mr. Silva Neto’s assistants.
According to investigators, Smart Tax, a company owned by Mr. Silva Neto’s mother, acted to speed up requests for recovery and release of ICMS credits, allowing companies to offset tax paid on goods purchased and avoid cumulative taxation along the production chain.
Claiming ICMS credits is legal and common among retail and service companies. The tax amount listed on purchase invoices is deducted from the ICMS owed in the monthly calculation. However, companies must obtain authorization to use the accumulated balance.
Valor reviewed documents from the Prosecutor’s Office to map out the alleged players and steps in the suspected ICMS credit fraud. The investigation is ongoing, and further analysis will follow.
Artur da Silva Neto – Supervisor at the Tax Oversight (DIFIS). Allegedly guided his team, compiled documents, and authorized ICMS credit releases. He is also accused of expediting proceedings at the Finance Department for the retailers, advising them on how to respond to suppliers’ questions about credits and what information to provide to the tax authority. According to prosecutors, he arranged for the hiring of law firms Fernando Capez and Advocacia Mocelin to act on Ultrafarma’s behalf. The firm did not comment.
Marcelo de Almeida Gouveia – State tax auditor with the São Paulo Finance Department in Osasco. Allegedly handled Fast Shop’s pending tax issues involving the Osasco tax office and assisted in responding to official notices about the company’s tax payments.
Company identified as the operator of the alleged scheme since at least 2021.
Kimio da Silva – Retired public school teacher, controlling shareholder of Smart Tax, and mother of Mr. Silva Neto. Allegedly transferred money from the company’s account to her son’s account to pay his expenses.
Smart Tax secretaries/assistants – Prepared tax services for Fast Shop and Ultrafarma using personal email accounts (@gmail, @terra, @uol). They allegedly had Ultrafarma’s digital certificate installed on a computer to expedite processes. Another certificate, from the Rede 28 fuel chain, was also found. Neither company commented.
Mário Gomes – Director with responsibility for the company’s liabilities. Allegedly led core negotiations with Mr. Silva Neto, appearing in email exchanges involving Smart Tax assistants and Mr. Silva Neto.
Fast Shop tax analysis department – Allegedly sent periodic ICMS-ST refund files to the auditor for review, labeled “Cat 42” or “txt Cat42.”
Fast Shop tax coordination department – Allegedly attended meetings with Mr. Silva Neto to define bribes, working with other Fast Shop members and the auditor to distort ICMS refund procedures. In one email, a tax coordinator reported offsetting R$8 million in tax for the electronics retailer.
Sidney Oliveira – Founder and CEO. Frequently copied on messages between Ultrafarma’s tax department and the tax auditor, allegedly showing awareness of the scheme, according to prosecutors. Allegedly oversaw developments to ensure the deal was being carried out. The company did not comment.
Tax and accounting department – Allegedly led operational aspects of the scheme. The department head allegedly decided which ICMS credits to request for reimbursement based on Mr. Silva Neto’s instructions. Many of Mr. Silva Neto’s messages were addressed solely to Ultrafarma’s tax director.
