Next Generation Partners

Firms To Watch: Tax

Deloitte Legal Guatemala‘s active tax controversy practice frequently teams up with practitioners from the firm’s consulting arm to handle disputes relating to income tax, VAT and transfer pricing.

Tax in Guatemala

Alta QIL+4 Abogados

Alta QIL+4 Abogados fields a diverse tax team, which is equally adept at handling tax structuring, litigation and compliance, with a strong emphasis on international tax matters. Benefitting from the firm’s top-tier banking and corporate departments, the team is well equipped to assist a host of large multinationals with the tax optimisation of financial and corporate transactions, including global restructurings, although it also advises on local matters. On the contentious side of the practice, the firm has established an impressive track record in contentious-administrative litigation against the Guatemalan Tax Authority (SAT), as well as handling criminal cases. Advising on customs tax, transfer pricing and tax compliance also makes up a significant portion of the team’s workload. José Quiñones, whose broad experience encompasses transactional tax and compliance matters, heads the team, while up-and-coming associate Otto Ardón frequently takes the lead in tax disputes.

Practice head(s):

José Quiñones


Testimonials

I think the main thing is trust – the Alta QIL+4 team inspires trust, loyalty and hope. My account is attended to by José Quiñonez and Otto Ardón, and they feel more like our in-house lawyers than external advisers. They ask questions, they know our business and they trust us to be transparent. They are very practical and proactive which at the end of the day is what you want.

What stands out is the confidence we have in working together and the ease of communication.

Key clients

Puma Energy


Naturaceites


British American Tobacco


24/7 Intouch


Copa Airlines


Bancolombia


Aceros de Guatemala


Grupo Gentera


PepsiCo


Abbott Laboratories


Frito Lay/Quaker Oats


Ternium


Telus International


Comercializadora Campbells


Work highlights


  • Advised Bancolombia on the collection of the credit guarantee of an ongoing real estate project.
  • Acted for 24/7 In Touch in litigation against the tax authority due to the adjustment of a VAT credit reimbursement originating from a challenge to the existence of export operations.
  • Acting for Naturaceites in litigation over the adjustment of profits income tax.

Arias

Arias has a full-service offering and network of offices across Central America, making it a strong choice to advise foreign investors in the region on the gamut of tax issues. The team acts as local counsel to an array of prominent multinationals on cross-border M&A transactions, as well as assisting with restructurings and compliance, and it is also a standout in customs matters. The firm is equally active in tax litigation, leaning on the vast expertise of dispute resolution head Mario René Archila to handle complex contentious-administrative cases against the SAT. At the helm of the practice, Ximena Tercero is well versed in transfer pricing, tax structuring and litigation. She is supported by a capable pool of junior lawyers, including senior associates Elisa Lacs, a specialist in customs tax, and the recently promoted Claudia Vega, and associate Estaymer Mendoza, who joined the firm from an in-house role at Grupo CFE in June 2022.

Practice head(s):

Ximena Tercero


Consortium Legal

Consortium Legal is renowned for the depth and breadth of its tax offering, using the firm’s full-service and multi-jurisdictional model to its advantage when advising on a wide range of local and cross-border tax matters. Commended by clients for its ‘knowledge and experience in international taxation‘, the team frequently advises on the tax aspects of foreign investments, including M&A and real estate transactions, and related issues such as customs tax and transfer pricing. The firm also has an enviable reputation in tax litigation, handling both civil and criminal cases before Guatemala’s highest courts. The four-partner team includes Alfredo Rodríguez (who has extensive experience in transactional tax), Olga María Meléndez (a standout in both contentious and non-contentious matters), Mario Estuardo Archila (a high-profile name for tax disputes) and David Erales (who leads the tax litigation practice). Associate Alejandra Fuentes-Pieruccini garners praise for her expertise in cross-border matters.

Practice head(s):

Alfredo Rodríguez; Olga Meléndez; David Erales; Mario Estuardo Archila


Testimonials

Consortium’s knowledge regarding the subject of taxation is invaluable. They definitely have the desired and required expertise, which gives clients peace of mind.

I like that they follow up on cases, in addition to the fact that their knowledge of the subject is indisputable.

Our requirements are attended to quickly. Knowledge and experience in international taxation.

Alejandra Fuentes-Pieruccini has knowledge and experience in international taxation, which allows her to provide advice in this area. Her assistance and availability to attend to the client’s needs undoubtedly make her stand out.

Key clients

Citibank


Colgate-Palmolive


Banco de los Trabajadores


Lancasco


Banco Industrial


CMI


Grupo Cofiño Stahl


Tigo


United Airlines


Grupo Tecún


PepsiCo


Radio Televisión Guatemala


Televisiete


Desarrollos San Jose


Asociación de Azucareros de Guatemala


Asociación de Importadores de Vehículos


Inversiones y Bienes del Atlántico


Spectrum


Asociación de Importadores de Motocicletas


Fresh del Monte


Sopesa


Grupo Lattice


Grupo Entero


Grupo Licorero de Guatemala


Banco de Antigua


Work highlights


  • Advising a fintech client on the application of VAT law.
  • Advising a real estate developer on the new criteria regarding capital gains tax on the transfer of real estate.
  • Advising vehicle importers and distributors on the proposed tax exemptions on electric and hybrid cars.

Mayora & Mayora, S.C.

Sought out by clients for its ‘quality, empathy and agility‘, Mayora & Mayora, S.C. handles the full spectrum of transactional, contentious and compliance-related tax matters. Tax litigation is a clear forte for the team, with its recent caseload featuring a number of complex disputes over customs and transfer pricing issues. As a member of Lataxnet, the Latin American network of tax-focused firms, it also enjoys close links with international practices, which it draws upon to assist clients with cross-border tax planning and international trade matters, in addition to joining up with the firm’s offices in El Salvador and Honduras to advise on regional tax strategies. Both renowned practice head Eduardo Mayora and Juan Carlos Casellas bring noteworthy experience with the SAT to the table, Mayora as a former board member and Casellas, who specialises in transfer pricing and tax litigation, as an in-house adviser.

Practice head(s):

Eduardo Mayora


Testimonials

The team stands out for the quality of the partners and associates and their high level of availability to attend to issues personally.

Quality, empathy and agility in response to our requests.

Key clients

Banco Industrial


Cindu de Guatemala


Ingenio Palo Gordo


Bolsa de Valores Nacional de Guatemala


Pochteca Guatemala


Elevadores Otis


Belcorp


Consolidados 807


Refractarios Nacionales (Morgan Thermal Ceramics)


Work highlights


  • Acted for Pochteca Guatemala in a dispute with the SAT over the classification of the tariff for the import of sodium from the US.
  • Defended Elevadores Otis against adjustments to its 2018 income tax due to a variation in the accounts in the general ledger.
  • Advised Consolidados 807 on tax issues relating to the return of merchandise which was wrongly delivered to the client in Guatemala rather than its Costa Rican subsidiary.

EY Law Central America

Praised by clients for its ‘experience in all tax and customs issues‘, EY Law Central America leverages its regional and global networks to advise an array of multinational clients on tax matters throughout Central America, Panama and the Dominican Republic. The team is widely recognised for its strengths in tax advisory work (particularly assisting with the due diligence and structuring of M&A transactions), compliance and transfer pricing, but also has a rapidly growing tax controversy practice. Guatemala managing partner Manuel Ramírez steers the team and has strong skills in international taxation and transactional tax; he is supported from the Costa Rica office by managing partner for Central America Rafael Sayagués and Randall Oquendo, who leads the tax controversy practice in the region. Experienced senior manager Ana Alfaro and manager Carlos Díaz-Durán are the key names to note for tax litigation.

Practice head(s):

Rafael Sayagués; Manuel Ramírez; Randall Oquendo


Testimonials

The experience in all tax and customs issues and the service is the best.’

Knowledge, attitude, service and punctuality.

Key clients

Aldesa Construcciones


Chevron Petroleum


CMI


Kellogg’s


Syngenta


Telus International


Millicom


Avon


BASF


Pfizer


A. D. Sosa & Soto

A. D. Sosa & Soto is skilled in both contentious and non-contentious tax matters, with an emphasis on advising international companies on the tax structuring of their operations in Guatemala. In addition to assisting with the tax elements of corporate transactions, the team handles a steady stream of disputes with the SAT and has a growing compliance dimension to its practice following the arrival of director Giovanna Menegazzo from Deloitte Legal Guatemala in October 2022. The department is jointly led by Einar Klanderud, whose practice spans tax litigation and compliance, and Juan Pablo Ortiz, who is able to draw on extensive experience as a former general counsel to the SAT and an in-house tax manager for various multinationals.

Practice head(s):

Einar Klanderud; Juan Pablo Ortiz


Testimonials

Juan Pablo Ortiz has an excellent relationship with the tax authority which makes doing business in Guatemala more efficient.

BLP

BLP‘s tax team has robust experience in advising large regional and multinational clients on tax compliance and planning, and the tax elements of M&A and corporate restructurings, frequently joining up with the firm’s busy corporate and finance departments, as well as its broad network of regional offices, to assist with multi-jurisdictional matters. Tax disputes also form a key pillar of the practice, and the team is active in challenging audits conducted by the tax authority. María Inés Arenales is the key contact in the department, with a broad tax practice that is supplemented by her strength in corporate and financial matters.

Carrillo & Asociados

Carrillo & Asociados‘ tax practice is largely focused on litigation, reflecting a firm-wide emphasis on this area; the team, which stands out for its ability to handle both contentious-administrative and criminal proceedings, has a strong record in cases relating to the payment of VAT, customs issues and challenges to audits by the SAT. The key name to note at partner level is Rodrigo Callejas, who leads the strategic litigation practice and has considerable expertise in fraud investigations. The talented cohort of lawyers includes senior associate María de Lourdes Villanueva, a specialist in tax, customs and international trade matters, as well as estate planning.

Lex Atlas

Founded in October 2022 by lawyers from the Guatemala office of Sfera Legal, Lex Atlas has a busy tax litigation practice, benefitting from the dispute resolution expertise of managing partner Ignacio Andrade Aycinena and the international experience of practice head Jorge Asensio Aguirre. The team routinely represents local and foreign companies in disputes with the SAT relating to income tax, VAT and tax exemptions, and also handles a high volume of criminal tax litigation, including customs fraud and tax evasion cases. Other key names include senior associate Luis Enrique Solares and associate Dinora Ceijas, both of whom are experienced in administrative and criminal tax litigation, and associate María Elena Vásquez, who focuses on tax advisory work.

Practice head(s):

Jorge Asensio Aguirre