PINHEIRO NETO - ADVOGADOS



                                                      Sao Paulo, April 23, 2002


Companhia de Saneamento do
  Parana - SANEPAR
Rua Engenheiros Reboucas, 1376
80215-900 Curitiba-Parana
Brazil

Ladies and Gentlemen:

                  We have acted as Brazilian counsel for Companhia de Saneamento
do Parana - SANEPAR (the "Company"), in connection with the issuance and the
sale of American Depositary Shares ("ADSs") each representing ten preferred
shares with no par value (the "Preferred Shares") of the Company. We refer to
the prospectus (the "Prospectus"), in particular to the section of the
Prospectus entitled "Taxation", which makes reference to the opinion rendered
herein below, forming part of the Registration Statement on Form F-1 filed by
the Company with the U.S. Securities and Exchange Commission (the "Registration
Statement") to effect registration of the ADSs pursuant to the Securities Act of
1933, as amended (the "Securities Act"), and the rules and regulations
promulgated thereunder, and any amendments, including post-effective amendments
and supplements thereto, and any registration statements filed pursuant to Rule
462(b) of the Securities Act related thereto.

                  We have examined such documents, records, and matters of law
as we have deemed necessary for purposes of this opinion, and based thereupon we
are of the opinion that the discussion in that section accurately reflects the
material Brazilian income tax consequences of an investment in the ADS by
persons not resident in Brazil for tax purposes.

                  We hereby consent to the filing of this opinion as Exhibit 8.2
to the Registration Statement.

                                                  Very truly yours,

                                                  /s/ Pinheiro Neto - Advogados
                                                  -----------------------------
                                                  Pinheiro Neto - Advogados