The Legal 500


Colombia > Tax


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Leading lawyers

Lewin & Wills, Abogados has ‘undertaken an entire range of work for us, from the interpretation of norms and analysis of new legislation to inter-company tax structuring and tax planning, taking into account transfer-pricing matters and the possibility of a global audit, we feel very well supported’. Clients further highlight the ‘professionalism and sophistication’ of the 11-strong team, noting its ‘very fine service’ provision and ‘permanent availability for consultations’. Recent work has involved advice on market exit; on domestic and cross-border M&A tax structuring; and the design of estate-planning structures, among other work; and the team also ‘combines its tax expertise with foreign exchange, corporate and even accountancy matters very well’. Covering every aspect of the practice, from transactional tax structuring to treaty taxation, and from transfer pricing to tax controversy and compliance, it has developed a truly impressive client list including UBS, Deutsche Bank, RBS, Standard Chartered, HSBC and BBVA, in the banking sector alone. A former president of both the IFA and the Colombian Tax Law Institute, founding partner and tax practice head Alfredo Lewin is a ‘very sophisticated lawyer’ and ‘a near-legendary figure’. His practice focuses upon inbound and outbound cross-border tax structuring. Qualified in New York and Illinois as well as Colombia, younger partner Adrian Rodríguez has extensive US experience and is ‘a dedicated and effective advisor’ much sought-after for his ‘intelligence, clarity and responsiveness’. The firm is also a founding member of the Latin American Tax & Legal Network (LATAXNET), which currently covers 17 jurisdictions in the region.

Posse Herrera Ruiz’s tax practice is ‘very similar to a Big Four firm in terms of understanding the clients’ needs, communication and strong technical background’ and clients profess themselves ‘very impressed by its approach’. Exhibiting ‘above-average service’ and ‘sharp knowledge of all-things fiscal’, the well-consolidated, 16-strong team works throughout the sector, be it transaction-related, general consultancy (including treaty and convention work), litigation, wealth management and planning, or transfer pricing (and associated litigation). Clients highlight ‘strong know-how and practical expertise in dealing with questions associated with transactional tax matters, particularly on the structuring and foreign exchange aspects’. Recent headline instructions have involved precisely this area, with the team advising Corpbanca on the tax structures for its $1.2bn purchase of Grupo Santander’s Colombian subsidiaries and its $1.28bn purchase of Helm Bank; and acting for Cencosud on the tax aspects of its $2.6bn acquisition of Carrefour. Other matters included the restructuring of COPEC’s Colombian holdings so as to maximise efficiency and facilitate the merger of Terpel and Gazel. Clients ‘would certainly recommend the practice to other companies’. Simply ‘outstanding on tax matters’, department head Juan Guillermo Ruiz’s election as IFA vice-president for Latin America, is a reflection of his regional standing. Senior associates Felipe Aroca and Juan Guillermo Becerra are highlighted ‘for their strong technical support’.

Efficient agile and committedBaker & McKenzie S.A.S.’s tax practice ‘generates absolute confidence’. Its lawyers are ‘personable and friendly’ and provide ‘permanent feedback and follow-up on matters entrusted to them’. Recent work highlights include structuring both the $2.6bn sale of Carrefour and Telefónica Móviles’ $750m issuance; advice on business structuring to Jerónimo Martins, Prebuild and others; and on the structuring of both funds and their investments on behalf of Altra Investments. A former managing partner of the legal and tax areas at Deloitte and Andersen, the ‘deeply experiencedJaime Vargas is ‘absolutely first rate’ and ‘thoroughly recommended’. Senior associates Jaime Girón and Ciro Mezza were both formerly at Deloitte: Girón heads up the tax litigation practice, and Mezza, who was previously also at Godoy & Hoyos Abogados and Araujo Ibarra & Asociados S.A, has an international trade aspect to his practice.

The ‘outstandingBrigard & Urrutiais a top-notch firm in general and the taxation area is no exception’, comment clients who also consider ‘the relation between the value of its advice and its fees as fair and reasonable’. Providing ‘consistently excellent and timely service’, the tax team is ‘very knowledgeable’, its advice ‘appropriate and precise’, and the ‘thorough attorneys’ are ‘keen to consider and explore all options in order to provide the best results for the client’. Recent work includes tax planning advice to: CI Prodeco, in relation to a $600m port development; Lafrancol and Correval, on the structure of their respective $522m and $72m sales; and EPM and Isagen on holding structures for their respective $500m investments outside Colombia. In all the above cases, the team was subsequently appointed as the client’s permanent tax advisor. An ‘excellent tax lawyer’, departmental head José Andrés Romero is ‘quick, practical, creative and has very good knowledge’; and dual-qualified senior associate Lucas Moreno is also ‘singled out’ as noteworthy. ‘They are both knowledgeable and dedicated attorneys with excellent work ethics and communication and management skills, and who go above-and-beyond to provide the best advice and first-rate service to their clients’.

Gómez-Pinzón Zuleta provides ‘fantastic support and assistance across the board’. The tax practice is experienced in planning, design and structuring issues, has notable tax-litigation strength and also works with external economic specialists so as to provide full transfer-pricing services. Described as ‘efficient, knowledgeable and hardworking’, the team is ‘a hugely reassuring ally’; and the firm’s membership of Taxand gives it genuine regional reach. Recent highlights include acting as Colombian tax counsel to Helm Corporation, on the $1.28bn sale of Helm Bank; advising BTG Pactual on its acquisition of a majority interest in Bolsa y Renta; and acting for EBX on the acquisitions of Calvista Gold and Galway Resources. In contentious matters, the team advised AIG on transfer pricing and income tax issues in the first dispute concerning the application of transfer pricing regulations to the insurance sector; the case is presently at the Council of State. ‘Arguably one of the best lawyers I have ever worked with’, departmental head Mauricio Piñeros is ‘a simply brilliant tax lawyer’. With over 25 years’ experience, he is recognised as ‘a deeply impressive practitioner’ by clients and peers alike. His fellow partner, tax litigation and transfer pricing specialist Álvaro Andrés Díaz, is ‘increasingly prominent’; and senior associate Ignacio Vélez is also noted.

Recommended without doubt’, the ‘well-known and reputableprietocarrizosa is ‘one of the top tax firms in Colombia’. In addition to advice on structuring and planning matters, the practice has a ‘standout’ tax litigation capability and provides transfer pricing services in conjunction with Charles Rivers Associates. Moreover, after two years as ambassador to Italy, Greece and the United Nations, founding partner Juan Manuel Prieto has returned to lead the firm’s private clients practice. Recent high-profile matters include the defence of Drummond in a $600m case against the tax authorities, currently the largest tax litigation in the country. The team also advised Goldman Sachs on the structuring of its multi-jurisdictional acquisition of Vale’s Colombian assets; acted for Banco de Peru on a reorganisation to optimise its fiscal position in Colombia; and advised Compañía Electrica de Sochagota, in a COP$8000m litigation against the tax authority where the team not only obtained a settlement in record time but also the paying of interest and the return of late-payment interest charges. Department head Martin Acero is ‘an excellent tax, as well as M&A, lawyer, he is quick, responsive and reads Anglo-Saxon clients very well, tailoring to their needs and concerns’; he is also ‘very knowledgeable on any issues related to international tax planning, inbound taxation and corporate reorganisations’. Senior associate Carolina Rozo is ‘a knowledgeable and responsive young tax lawyer with great potential’ who is increasingly coming to the attention of clients. Formerly at tax specialists Quiñones Cruz, Oscar González is also noted.

Active throughout the sector, the tax-focused boutique Cahn-Speyer, Paredes & Asociados, has profile for its work in relation to both inbound and outbound investment activity, restructuring agreements and litigious issues, including transfer-pricing litigation capability. Indeed, name partner Paul Cahn-Speyer is best known as ‘a top-notch tax litigator’, although his practice also extends to international taxation and trade and commerce issues. He also has a niche specialisation in sanctions related to the tax non-payment. Formerly at Andersen, senior associate Claudia Rodríguez has 20 years’ experience and is an integral part of the practice; ‘I have worked with her on various issues and she is excellent’.

Cárdenas & Cárdenas Abogados’ small but capable tax department handles predominantly transaction-related tax-due diligence, tax planning and structuring in support of the firm’s highly active corporate and finance practices. Recent work includes planning and structuring work in relation to Bolsa y Renta subsequent to its acquisition, and the structuring of issuances for Telefónica and Pacific Rubiales. A ‘firmly established presence’ providing ‘very appropriate advice’, the practice is led by the very well-regarded Camilo Cortes, who trained at eminent boutique Lewin & Wills, Abogados. The team also undertakes day-to-day tax advice and consultancy, reorganisations, administrative matters and tax litigation; clients highlight ‘outstanding service’ and ‘good value for money’.

Having formed an alliance with US firm Ryan (with which it shares a number of clients, such as Occidental and Exxon Mobil), Godoy & Hoyos Abogados is seeking to increase both its local and regional market share. Formerly an exclusively tax-focused boutique, the firm has broadened its service offering to include corporate, transactional and financing matters; nevertheless, it retains its full-service tax capability, now including transfer pricing, the firm’s strongest suit. Practice director Catalina Hoyos ‘provides fantastic support on all tax matters’, and is ‘perfectly capable of defending a position if required’. Juan Pablo Godoy is co-director of the tax practice and clients highlight his ‘excellent communication and complete mastery of the issues of a case, where his great experience allows him to grasp and summarise every issue in the correct manner’. Senior consultant lawyer Carlos Forero has ‘broad tax knowledge’ and ‘provides answers one can rely on and, perhaps his greatest strength, always goes straight to the point with clarity and certainty’.

With some corporate and investment-related work, Mauricio A. Plazas Vega Abogados & Asociados is principally recognised as a tax-focused boutique –‘and a very good one’. The 13-strong team also has expertise in areas frequently relevant to tax practice, notably constitutional and community law, the latter being of particular relevance given Colombia’s membership of the Andean Community. A former president of the Latin American Tax Law Institute, name partner Mauricio Plazas is regarded as the foremost expert on value-added tax (IVA), in the country. He also undertakes tax litigation.

While clients recognise Norton Rose Fulbright as ‘a new firm in the market’, they also note ‘its considerable experience at an international level’, and the experience it can bring to bear ‘that will permit it to build new relations and participate in the sizeable matters that are arising in the Colombian market’. The nascent tax team, currently two strong, is predominantly engaged in transaction-related matters at present, handling the tax aspects of Pacific Rubiales’ acquisitions of C&C Energía and PetroMagdalena, and advising Rellenos de Colombia on its sale, among other matters. A ‘recognised tax lawyer with experience in the operations undertaken by multinationals’, department head Benjamin Cubides’ ‘knowledge of tax law and structures, especially national and international tax planning issues, is of great assistance in operations undertaken in Latin America’.

Great independent advisors, particularly on tax issues relating to the finance sector’, Quiñones Cruz is a primarily tax-specialised boutique that advises on all aspects of tax advice and litigation, domestic and international tax planning and transaction-related tax advisory. It also specialises in arbitration and tax-related administrative proceedings, transfer-pricing litigation, and undertakes consulting for public policy design and constitutional tax law. Notable experience includes the tax structuring of the $1.3bn Oleoducto Bicentenario project; and on the contentious front, successfully litigating a landmark $500m case establishing the territorial distribution of business tax for mobile telecom services (on behalf of COMCEL). The firm’s visibility in leading contentious cases is complemented by its profile in public policy matters, and the firm recently advised both the national government and the National Federation of Departments on recent tax reforms. Providing ‘extraordinary levels of service’, founding partners Lucy Cruz and Antonio Quiñones focus upon tax planning and structures, and litigious matters, respectively. Quiñones is also a specialist on tax-related constitutional issues. A member of the drafting commission of the Latin American Tax Institute, Natalia Quiñones Cruz is also noted.

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