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Founded as an accountancy firm 35 years ago, Chévez, Ruiz, Zamarripa y Cía SC has offered legal tax services for over twenty years, and has long been the dominant player in the sector. The firm numbers some 400 professionals -200 of whom are lawyers- and offers unparalleled depth in its core areas: legal tax consulting and litigation, transfer pricing, social security related tax-matters, and international trade. The firm has a strong position with domestic Mexican clients, particularly in the financial services, real estate and retail sectors. Recent mandates on the transactional side saw the firm act as tax advisor to NSC Asesores, México’s largest independent financial advisory and portfolio management firm, in relation to a buy-in by Julius Baer Group; and to a local pharma group in relation to its possible multimillion-dollar sale. The ‘first class’ and ‘deeply experienced’ Ricardo Rendón is particularly noted for his transactional work; others of note for consultancy matters include René Meza for tax planning and Samy Lazarov for wealth management and estate planning. On the contentious side, the firm has been particularly active with (tax ombudsman) PRODECON-sponsored ‘acuerdo conclusivo’ mediated final tax agreements; originally introduced in 2014, the firm was –fittingly- the first to complete one of the ADR processes. Today it has 100 such cases in process. Key contentious and litigation-side professionals include ‘renowned’ practice head Manuel Sainz; and ‘seasoned professionals’ Alejandro Torres and Ricardo Cervantes – all of whom have more than 25 years’ experience. Also noted are the younger, litigation-focused partners César de la Parra, Juan Pablo Lemmen and Eugenio Franzoni in the firm’s Mexico City, Querétaro and Monterrey offices, respectively. The firm has not been untouched by the tumult seen in the tax market over the last couple of years and the departure of Juan Carlos Guerrero from the firm’s New York office in late 2015 was a loss. Eduardo Valenzuela, a tax consultant from the firm’s Mexico City office, has replaced him; in addition to his expertise in real estate and M&A transactions, and the finance and energy sectors, Valenzuela also leads the firm’s FATCA and CRS practice. The firm also scored a notable success with the recent hire of Armando Lara, a former director general of for international treaties in Ministry of Finance’s Under ministry for Revenue who has considerable experience of double taxation, exchange of information agreements, tax policy design and international tax issues. The firm also has an active anti-money laundering practice led by Daniel de la Parra.

Strongly focused on adding value and providing personalised service’ according to clients, Turanzas, Bravo & Ambrosi is increasingly seen as ‘a reference point among legal tax boutiques’. Indeed, the firm was appointed the Mexican member of the tax-focused LATAXNET tax and legal alliance in 2015 and has proved resilient in today’s difficult market. Currently 32-lawyers strong, with seven partners, the firm’s service offering covers tax consultancy, tax litigations and planning, and domestic and international tax matters. The firm’s strength derives from the complementarity of the partner’s specializations – both in terms of industry sector and specialised tax expertise. ‘First-class practitioner’ Mauricio Bravo undertakes corporate, indirect, and both local and international taxation, as well as individual wealth management and estate planning; his ‘particular expertise’ in financial sector tax matters is also highlighted. ‘A stand-out figure’, Mauricio Ambrosi focuses on tax litigation, international taxation (particularly in relation to the marine and transportation industries and the pharma sector), and also undertakes consultancy relating to transfer pricing. Ángel Turanzas has deep involvement in the direct sales sector, where the firm has a strong presence, and also handles oil and gas matters; and Pedro Ramírez is primarily engaged in private client / wealth management matters, a niche where the firm has a highly reputed practice. Younger partners Jorge Cabello and Jorge Fuentes -who was appointed to the partnership in early 2016- undertake primarily tax litigation and administrative representation, while Francisco Ortega works primarily on the consultancy side, particularly in relation to corporate advice, direct sales and infrastructure projects. The firm’s recent matters include acting for shipping lines including Maersk, Hapag Llloyd and Hamburg Sud in relation to a VAT dispute; ongoing general corporate tax advice to the Pearson Group; the design of a tax-efficient strategy for Bancomex, and successful precedent-setting litigation on behalf of Latam Airlines Group.

A market leader for contentious matters’, 18-strong specialist tax boutique Arias, Meurinne y Rodríguez, S.C. has built an enviable reputation for its complex litigation capability; indeed, its partners’ ‘hands-on service’ and ‘sound strategies’ saw the firm win over $1bn in litigation during the last year. Unsurprisingly the firm has developed an impressive client roster, particularly across the automotive, pharmaceutical and telecoms sectors. Key to this success, the ‘intellectually sharp and always well-prepared’, Pedro Arías is ‘definitely one to have on your side’ according to commentators; head of the firm’s litigation team, his practice also reaches into constitutional and administrative challenges. Highly regarded by peers and clients alike, name partner Humberto Rodríguez and Salvador González Escamilla are also both ‘formidable litigators’. While some 70% of the firm’s workload is made up of contentious matters, it also undertakes consultancy, particularly in relation to tax efficiency. Here, name partner Luis Meurinne is the key figure: ‘well respected’, he ‘goes that extra-mile to ensure a successful outcome’. Other figures of note include junior partner Pamela Orozco; and senior associate Leah Sánchez; formerly at the tax prosecutors office (procuraduría fiscal), Sánchez is identified as ‘a brilliant prospect’. The firm further strengthened its second line with the reincorporation of Elizabeth Lastra Gonzalez in late 2015.

Good and present’, Baker McKenzie S.C. fields an 80-strong practice group spread across five offices. Its primarily foreign clientele appreciate that the firm has ‘all the advice services in-house (from modest compliance services work to assisting with strategic items)’, noting that it displays ‘thorough tax and industry knowledge’ and demonstrates ‘the skills to bridge the cultural gap from Europe (or US) to Mexico’. Key figures in the sizeable group include practice coordinator and head of tax compliance, Héctor Reyes; head of the firm’s regional transfer-pricing practice, Moisés Curiel (whose recent mandates include advising on bilateral anticipated transfer pricing agreements); and Jorge Narváez, who is increasingly focused on tax/corporate restructuring and tax litigation within the framework of the OECD’s BEPS initiative. He is also chair of the firm’s global, tax dispute-resolution practice and leads on wealth management matters. Transfer-pricing specialist Carlos Linares is gaining profile; his ‘very good analytical skills’ enable him to ‘see the big picture quickly’, ‘put complex items in perspective’ and ‘connect to and deal with foreign tax systems’. Also highlighted is Luis Carbajo, ‘an all-round international tax professional and strategic player who is knowledgeable about the business/tax playing field’ and ‘easily adapts to changing circumstances: he’s able to make the difference in a closing’ noted one client. The team’s recent mandates include numerous transfer pricing audits and administrative challenges to tax assessments, as well as matters concerning tax audits, structuring, tax-led reorganisations and the off-setting of double excise tax. The team also recently won a major administrative case in the hydrocarbons sector. Other notable figures include tax consultancy specialists Luis Adrián Jiménez and Jesús Alvarado; the tax strategy and litigation-focused Ulises Castilla (who recently made partner); Armando Cabrera for transfer pricing; Alberto Polanco and Ronaldo Moya on advisory and general tax planning matters; and Roxana Massiel on contentious and administrative tax matters, including ‘amparos’.

Long reputed in the sector, Basham, Ringe y Correa, S.C. fields a 25-strong practice which offers a full range of advice and consultancy and has ‘stand out contentious capabilities’. The department’s stellar corporate client list includes the likes of Volkswagen, Colgate-Palmolive, Goldcorp and Sumitomo (on the international side), and Grupo Herdez and Aeroméxico (locally), which it serves from offices in Monterrey, Querétaro and Mexico City. Recent matters include a major restructuring in the extractive sector, the development of a tax-efficient, multi-jurisdictional JV structure, tax advise to the sellers in a significant local divestment; and a challenge to a shift in the interpretation of a transfer-pricing regulation concerning ‘related parties’. On the contentious side, the team has been highly active with administrative appeals (particularly in relation to VAT refund denials) and ‘acuerdos conclusivos’, as well as undertaking one-off/precedent-setting cases regarding matters such as the deduction of pro-rata expenses, the interpretation of article IV of the single rate Business Tax Law. The team also undertook a challenge to the soft drinks’ “sugar tax” implemented -on health grounds- in 2014. Recently elected Chair of Lex Mundi’s tax committee, Gerardo Nieto is ‘hugely experienced’ and undertakes tax consultancy and litigation, as well as advisory on tax audits, restructurings and planning. ‘He’s a stand out figure for contentious matters – he’s very capable’, commented one peer. With a strong focus on complex tax litigation, Gil Zenteno provides ‘fierce defence of his clients’ position’ according to clients. Head of the firm’s tax consulting, planning and strategy practice, ‘recognised market figureAlejandro Barrera is ‘a no-nonsense tax advisor’ and ‘very talented’. Also noted are Victor Barajas and Mario Barrera who focus on wealth planning / private clients, and transfer pricing matters, respectively. The team is also noted for its expertise regarding the automotive industry, the mining sector (a true niche in the Mexican market), and corporate restructuring/reorganisation-related tax matters.

Always available and responsive’, and with ‘amazing commitment to its clientsCreel, García-Cuéllar, Aiza y Enríquez, S.C. provides ‘excellent service’ and ‘expertise in all tax matters’. Arguably the corporate firm that has been most successful in its establishment of a tax department recently, the practice continues to grow and now numbers 20 lawyers, including three partners. An accountant as well as a lawyer, practice head Alejandro Santoyo (‘a brilliant incorporation’), is ex-JP Morgan and has extensive knowledge of the financial sector. His recent mandates include leading the team acting as tax counsel to First Reserve and BlackRock on their $900m acquisition of a 45% stake in the Los Ramones II natural gas pipelines project; and as counsel to AT&T on its $1,875bn acquisition of Nextel (Mexico) from NII Holdings. A former tax director at General Electric, Omar Zuñiga has extensive in-house experience and recently led advice to Blackstone on the execution of three separate credit facilities -totalling $3.5bn- for the acquisition of GE Real Estate (Mexico)’s lending platform and commercial real estate mortgage loans portfolio. A former assistant deputy commissioner at the SAT and OECD consultant, Jorge Correa has deep public sector knowledge as well as both financial and energy sector expertise. His recent mandates include working alongside Santoya on the Los Ramones pipeline acquisition, as well as on CKD Infraestructura México’s acquisition of a 49% stake in CDPQ’s equity investment in newly formed joint venture company, OVT. Significantly, the practice also provides day-to-day advice on a full range of tax matters to a high profile clientele. Recent non-transactional matters include advising Deutsche Bank on Mexican tax obligations arising from its global corporate restructuring; Sierra Oil & Gas in relation to the Round 1 bidding process, and TransCanada Mexico on its day-to-day operations. Other matters included advice to Diageo (Mexico) on excise tax and post-closure issues relating to its acquisition of Tequila Don Julio; and Luxottica on corporate structures, corporate tax and VAT issues related to its business activities in the country. Additional key figures in the team include counsel Ericka Gonzalez, and senior associates Luis Vásquez (who heads the as-yet small, contentious tax practice) and Eduardo Michan. The team’s ongoing growth also saw the noteworthy incorporations of former chief advisor to the head of the SAT, Nadja Ruiz (she joins the firm as a senior associate and brings particular knowledge of FATCA, CRS and tax treaty interpretation); and mid-level associate Andrés Sánchez Hernández, a former head of the “acuerdos conclusivos” team in the SAT’s large tax payers’ department.

Arguably the foremost of the “big-4” across the region, Ernst & Young’s aggressive growth has seen it position itself strongly over the last two years – particularly since it incorporated the former Forastieri y Roqueñí firm, thereby boosting its corporate side capability. On the tax side, as is to be expected, the firm constitutes an impressive proposition. With 18 offices across the Republic and key outposts in Monterrey, Merida and México City, the firm offers ‘full-complement tax capability’. On the consultancy side, key figures include the tax and law services-manager for Mexico and Central America, New York-qualified Manuel Solano; particularly focused on planning in relation to cross-border acquisitions, he divides his time between New York and Mexico City. Head of business tax advisory Francisco Olivares and head of international tax services Koen van’t Hek are also both ‘strongly recommended’. Van’t Hek has over 20 years’ tax planning experience and focuses primarily on transactional matters, tax efficiency (particularly in relation to supply chain management) and structuring. On the contentious side, partner-in-charge of tax litigation, Enrique Ramírez Figueroa is a ‘veteran figure’ who is ‘hugely respected’. Also noted is ‘highly experienced’ litigator Nora Morales, who focuses primarily on transfer pricing and tax treaty matters, particularly in relation to financial institutions. The firm’s energy industry capability is also highlighted: energy sector leader for Mexico and Central America, Alfredo Alvarez’s ‘impressive practice’ covers oil & gas, power, utilities and mining. Also noted is Houston-based Oscar López Velarde who has considerable involvement in Mexican energy matters, particularly in the hydrocarbons subsector. Head of private clients’ services, Elias Adam Bitar is ‘impressive’ and ‘very capable’. The Mexico City office’s legal practice was further boosted in early 2016 with the incorporation of Rocio Gonzalez Alcantara as head of regulatory matters and dispute resolution. Former transfer-pricing practice head Jorge Castellon Velarde left to join PwC in late 2015.

Frequently identified as a ‘relevant player’, 17-strong, boutique firm González Luna, Moreno y Armida has over 20 years in the market and is perhaps best known for representing its clients before relevant (administrative and tax) authorities. Nevertheless, its service offering stretches across tax consulting, tax litigation, and foreign trade & customs. The team is also noted for the depth of its advisory capabilities, which cover the interpretation and application of Mexican tax legislation (and associated treaties), administrative tax law, capital gains, federal income tax, property tax, VAT and both local and cross-border planning for residents and foreign tax payers. A former associate director-general at Mexico’s SAT, the ‘impressive’ Ramiro González Luna focuses on tax advice and consultancy, particularly as regards corporate and international tax matters. He is strongly recommended both for transactional work and for structuring, particularly in relation to FIBRAs (he worked on Fibra Hotel and Fibra Danhos, for example); indeed, recent matters include advising Fibra Uno on the tax aspects of its $2.1bn acquisition of a real estate portfolio from MRP. On the contentious side, the firm fields an impressive front line including tax controversy specialist Diego Armida (‘a powerful litigator’), and Luis Carlos Moreno, whose broader focus takes in administrative tax matters, litigation and international trade and customs. Also noted are senior associates Fernanda Estrada and Cristina De la Torre. Other key clients include Evermore.

With ‘great levels of service, responsiveness and diligenceJáuregui y Del Valle, S.C. continues to consolidate its tax offering and recently incorporated a senior counsel focused on contentious work in the sector. With the exception of transfer pricing, the team provides the full range of tax services but has a strong emphasis upon structuring work, particularly in relation to funds, and on wealth management and patrimonial planning. Practice head Luis Gerardo del Valle Torres is ‘intelligent, smart and strong’; while he also undertakes corporate tax consultancy and litigation, he is best known for his ‘strong practice’ in the private client and wealth planning subsector. He is currently advising CKD’s Finsa, Planigrupo and Walton on a complex income tax refund process. ‘Very good’ corporate tax specialist Eduardo Medina Zapata undertakes tax consultancy (including day-to-day matters) and has a particular focus on the structuring of funds (both private equity and public) and JVs. His current caseload includes advising FIBRA Terrafina on the tax structure for an industrial real estate portfolio acquisition, as well as on the refunding of a $40m creditable VAT balance. A former president of upper chamber of the Federal Court for tax and administrative matters, senior counsel Luis Carballo leads the firm’s contentious tax practice. He is backed by Alejandro Segall who was appointed partner in 2015. The department’s capable second line includes senior associates Ricardo García (a former director of the Tax Advocate’s office), Laura González and Oscar Paz. In other matters the team has also been active in relation to challenges to Article 28 (sect XXX) of the country’s new Income Tax Law (dealing with the deductibility of employer’s payment).

Early adopterJones Day established its tax practice in 2011 and has consolidated an ‘efficient and capable’, 5-strong team that can also draw on the wealth of knowledge in the firm’s international offices. The local practice is principally oriented toward tax planning and transactional matters, but also undertakes tax audits and relevant administrative and regulatory issues. Recently promoted from counsel to partner, department head Rodrigo Gómez undertakes both tax consultancy (including planning and advisory) and tax litigation, as well as international trade and customs work. The team has been reinforced by the return of senior associate Luis Salinas from his LLM (and time at the firm’s New York and Washington DC offices). Recent headline transactional work saw the pair advise NII Holding on the $1.88bn sale of its Nextel business to AT&T, and undertake all the tax aspects of the sale of Radioshack’s Mexican assets to Office Depot (Mexico). The team also handles litigious matters where Gómez works in close conjunction with specialised associate Andrés Lieja. Other recent matters include ongoing advise to Toyota on the tax aspects of its participation in a JV; extensive tax litigation against assessments issue by the tax and social security authorities (SAT & IMSS); and advice regarding matters including federal tax incentives, tax treaty interpretation, maquiladora structures, advance pricing agreements and authorizations relating to federal tax payments. Other clients include: Lowe’s Corporation, American Standard, GTECH Corporation, GIC Real Estate and Renovalia.

Long highly reputed, the former Ortiz, Sainz y Erreguerena, now Ortiz Abogados Tributarios S.C. is undertaking a process of restructuring following the departures of José Miguel Erreguerena, Arturo Pérez Robles - Gabriela Pellón and junior partner Denise Lester in early 2016. As a result, the currently 11-strong, dedicated tax boutique is now largely litigation oriented –the sub-sector where it is best known and has long been ‘a reference point in the market’. ‘Brilliant’ name partner Gabriel Ortiz is ‘an excellent lawyer’ and ‘very well recognised for contentious tax matters’; a former president of the Mexican bar association (2013-15), his practice stretches across both contentious and advisory matters. Fellow partners Carlos Yáñez Alegría and Carlos Monarrez are also primarily dedicated to tax litigation, although Monarrez also undertakes tax planning. As noted, the firm is in the process of restructuring and new hires are expected. Pablo Ramirez Morales moved in house at ArcelorMittal Mexico in mid-2015.

PricewaterhouseCoopers, SC’s Mexican operation continues to consolidate its position amidst the turbulence of the tax sector with notable moves including Luis Felipe Muñoz García’s appointment as an international tax partner in mid-2015 and the subsequent incorporation of former Ernst & Young transfer-pricing practice head Jorge Castellon Velarde later the same year. Certainly, the firm continues to house considerable talent and experience in its network of 20 local offices across the Republic. Head of legal Eduardo Méndez Vital is ‘the cornerstone of the firm’s local legal practice’, and has over 30 years’ experience in consulting and litigation matters. Raúl Bolaños V is also ‘an absolutely key figure’; with over 25 years’ experience, he is active in both litigation and consultancy matters. Other recommended figures include José Antonio Garduño, in Monterrey; Carlos Manuel Martinez in El Paso; and Alejandro Aceves Pérez in Mexico City. Recent work includes acting as counsel for accounting and tax matters on Liberty Mutual’s acquisition of Surety Company. Also noted are senior associates Cynthia Angélica Covarrubias and Alberto Diaz de Leon. Clients include Aeropuertos Mexicanos del Pacífico, Médica Sur, Corporación GEO, The Pepsi Bottling Group México, Alsea, Samsung Mexicana, Tyco Electronics México and Grupo Marítimo Industrial.

The incorporation of high-profile figure Manuel E Tron at SMPS Legal late last year gave this unusual firm -it has offices in Calgary, Dallas, Mexico City and Bogotá- increased visibility. Tax, however, was already established as one of the firm’s core practices under the leadership of founding partner Jorge San Martin who is both an accountant and a lawyer. In addition to the arrival of international tax specialist Tron, 2015 also saw the hire of the similarly focused Ana Paula Pardo from Hogan Lovells BSTL, S.C., and the appointment of tax-litigation specialist Christian Solis as partner. Senior associate Federico Scheffler, who has a strong focus on advisory work, primarily in relation to M&A transactions and restructuring, completes the core of what is today an 18-strong team. While full service in tax matters (barring transfer pricing), the firm’s unique geographical footprint reflects its strong engagement with the energy, mining and oil & gas industries in particular and much of its work stems from these sectors and related corporate activity. In addition to general corporate tax advisory and transactional tax matters, other recent work includes: tax advice on financial structures involving trade receivables between different tax jurisdictions; advice on integration processes and the (tax efficient) structuring of Mexican entities; advise in connection with tax audits and assessments (and associated litigation); and the analysis of the tax consequences attendant upon the implementation of different corporate structures.

Customer service makes the difference’ at Sánchez Devanny according to clients. The firm fields a 15-strong team (with three partners) that undertakes both consultancy (advisory, planning) and tax and administrative litigation. The practice is led from Monterrey by Ricardo Leon, who is highlighted for his ‘expertise, knowledge’ and ‘comprehension of the problems’ presented. In Mexico City, the ‘very thorough’, Abel Mejia provides ‘solid pragmatic advice’, as does ‘committed and diligent professional’ Guillermo Villaseñor, who recently led a successful challenge against a tax assessment made by the State of Tlaxcala that sought to impose “a tax-like charge” for the installation of a sub-surface pipeline. As well as M&A matters (particularly tax advice relating to acquisitions), recent non-transactional work includes analysis of the Mexican tax system for potential investors and advise on a tax-free stock-for-stock swap. On the contentious side, matters include the successful pre-litigious overturning of a tax contingency assessment made by the SAT, and PRODECON-sponsored ‘acuerdo conclusivo’ procedures. Clients also highlight the ‘technically strong’ Humberto Morales for ‘corporate and compliance tax matters’. Tax counsel José Ángel Eseverri is also noted.

Mid-sized corporate player Creel Abogados, SC dedicates significant resources to tax matters, fielding a six-strong team that undertakes tax consultancy and litigation, transfer pricing and international trade matters. Key partner Carlos Martínez R is primarily focused on the tax aspects of M&A, capital markets and financing transactions; he recently led on matters including advice to Corporación de Restaurantes 2012 on the reorganization and sale of the US and Mexican assets of the “Doña Tota” fast-food chain; Grupo Escato on the tax aspects of its acquisition of an 80% stake in furniture design business, Kolo; and Portinox on the tax aspects of a cross border reorganization involving Mexico, Germany and Spain. With over 20 years’ experience, Javier Portas also undertakes transactional tax work but is principally focused on corporate reorganizations estate planning and tax litigation; he also leads on international trade matters. Key support comes from associates Carlos Pérez-Chow and Esteban Gómez Aguado. In other work, the team advised Almaden Minerals regarding ‘amparo’ proceedings concerning a mineral royalty and certain provisions of the new Income Tax Law; Istithmar World on the tax aspects of a debt refinancing and related tax audits and disputes with the SAT; and undertook tax litigation in relation to tax refund claims. Key clients include Bostik, Brown Forman Corporation, Eveready de México, Lafarge, Sodexo and Telefonica.

The Mexican office of Gardere Wynne Sewell, Gardere, Arena y Asociados S.C. is differentiated by its ‘genuine business orientation’, according to clients: it is ‘characterised by always thinking in strategic terms so as to find the best legal formula to obtain their clients objectives’. Moreover, clients further note that the firm provides ‘excellent service’ and ‘the response time and commitment of the entire team is really impressive’. Partners Roberto Arena and Fernando Camarena constitute the core of the 9-strong, Mexico City tax team and they can also draw on the know-how of a further nine tax partners in the firm’s Austin, Dallas and Houston offices. Both are characterised as ‘very competent and sophisticated in fiscal matters, not only in terms of local tax issues but also those that involve the US, providing a rounded service that fully covers both jurisdictions in a reliable and efficient manner’. Unsurprisingly, much of their work has a bi-national component, or indeed a link to the hydrocarbons sector. Recent matters, for example, include advising automotive-supplier Littlefuse on a complex restructuring involving its three Mexican (maquiladora) subsidiaries and the shift of their principal to the Netherlands; and tax advice to MTS Sistemas Solares in relation to a $70m insurance claim, and associated asset transfers and tax structure negotiations. Other work includes ongoing litigation on behalf of drilling company KCA Deutag regarding the leasing of a drill rig and involving double taxation issues; offshore transport services company Bristow Group, also in relation to leasing matters; and tax advice to a benefits carrier regarding the launch of new business lines. Specialised tax associate Aldo Mendoza is also noted.

Building upon the earlier return of practice head Arturo Tiburcio, the Mexican office of Hogan Lovells BSTL, S.C. has continued the re-development of its tax practice with the incorporation of Jaime Espinosa de los Monteros from Muñoz Manzo y Ocampo, SC in early 2016. Bringing a team of four associates (with a particular specialization in tax and administrative litigation matters), the new hires have significantly deepened the firm’s tax capability. Tiburcio has ‘considerable expertise’ in consulting, auditing procedures and contentious tax matters (particularly foreign investment and transfer pricing). Espinosa, in turn, has strong experience in both corporate and finance related tax matters, as well as in tax litigation. Recent matters include a tax-led restructuring; tax advice regarding a cross-border reorganization; advice concerning royalty issues in the mining sector; advisory concerning tax audits, PRODECON-sponsored ‘acuerdo conclusivo’ negotiations and successful tax litigation regarding disputed income tax assessments. Key support comes from senior associate Francisco Palmero, who handles consultancy litigation and auditing matters. Representative clients include: Lufthansa Global, General Electric, 21 Century Fox, Bonafont/ Danone, Federal Mogul and Goldman, Sachs & Co.

Led by Mariano Calderón, Santamarina y Steta’s six-strong tax department undertakes a caseload evenly divided between consultancy and planning, and contentious matters. While Calderón handles both litigation and some consultancy, the team also has recourse to the profound knowledge of senior tax counsel Agustin Gutierrez, ‘a legendary figure’ in the sector. Recent work ranges from advisory on cross-border transactions; international corporate restructurings, and analysis of the tax consequences of the execution of collateral, to the design, planning and implementation of tax structures for Mexican subsidiaries; tax litigation, VAT-refund related matters, ‘amparos’ and even some transfer-pricing related issues. Indeed, despite the team’s relatively small size, clients note ‘its ability to give all round, integrated service’ in the sector. Also noted is experienced senior associate Karina Robledo, who has extensive knowledge of transactional tax matters.

The arrival of former ‘OSE’-name partner José Miguel Erreguerena at Rizo Garza-Cantú – now Rizo, Erreguerena y Garza-Cantú, S.C. has significantly increased the profile of this small six-strong boutique, originally founded in 2013. The team provides ‘genuinely personalised service’, and handles local and international consultancy, restructuring and tax litigation, and has a particular niche on the tax impacts of Mexico’s energy reforms and PPAs, telecom-related tax issues and administrative tax matters. It is also knowledgeable regarding OECD norms, BEPS and international tax treaties and of late has handled numerous ‘acuerdos conclusivos’, the mediated tax settlements sponsored by PRODECON. Founding partners Juan Carlos Rizo and Carlos Garza both have over ten years’ experience within the SAT, Mexico’s tax authority, where Rizo undertook contentious matters (litigation and amparos), and Garza was more involved with norms, both domestic and international. Erreguerena joins the firm after almost twenty years at what was formerly ‘OSE’ bringing with him his first-class reputation for all aspects of consultancy work.

Von Wobeser y Sierra, SC’s compact but capable tax practice works across the entire sector, from consultancy to litigation, but has been particularly focused on transaction-related tax matters recently. Headline work saw the team advise BMW on all the tax aspects of its $1bn investment in new factory facilities in San Luis Potosi. However, the team has also been busy on matters including tax advisory related to cross-border acquisitions and asset purchases; tax strategy regarding investments, finance facilities and transactions; and analysis of the tax consequences of strategic acquisitions for clients including Coca-Cola, Mars, Anheuser Busch InBev, Skidmore, Triumph Group, Cementaciones Mexicanas and ICA. The core team is comprised of the ‘tremendously experiencedFernando Moreno, who has 30 years’ in the tax field and particular expertise in relation to treaty matters and double taxation. His fellow partner, Luis Miguel Jiménez focuses on strategy development and the origination of structures as well as on international trade matters. Senior associate Jorge Ricardo Díaz is also noted; his broad tax practice covers consultancy, litigation, social security matters and international trade, and he has niche expertise in the development of preventative strategies. Head of litigation Marco Tulio Venegas leads on contentious tax issues as required.

Best known for its telecoms practice, Acedo, Santamarina, S.C is a small firm ‘with real specialists and a professional approach’, according to clients who note it is ‘responsive’, provides ‘timely delivery’, and ‘continually meets expectations’. The small tax team handles tax advisory and litigation work, along with international trade matters. Departmental head Rafael Tena has ‘a great personality’ and ‘a practical approach to finding solutions’; notable recent mandates saw him file an amparo against regulations brought by the government of Mexico City levying a 1.5% tax on each fare charged by app-based taxi system, Uber. Other matters include administrative appeals against tax assessments, nullity suits against IMSS social security tax assessments, legal opinions regarding the application of VAT; contingency analysis; and constitutional challenges to article 28 (sect XXX) of the new income tax law and article 28 (sect IV) of the Federal tax code.

Founded in 2010, small fiscal boutique Calvo Nicolau y Marquez Cristerna-DFK, S.C. boosted its capacity recently, with the arrival of public accountant Layda Cárcamo from Chévez, Ruiz, Zamarripa y Cía SC. The firm covers all aspects of tax practice with 30-year veteran Oscar Márquez (who is both an accountant and a lawyer), leading on tax consultancy and planning, and his fellow name partner Enrique Calvo leading on tax litigation. Key associate Armando Peredes (who also has over 20 years’ experience), focuses his practice on administrative review and regulatory matters.

The Mexican office of Spanish titan Garrigues continues to consolidate its market presence and has built a small but solid tax team comprising four lawyers and two accountants. It houses considerable expertise across both consultancy and (administrative) litigation and has been active in M&A-related work in particular, along with planning and advisory matters. ‘A solid professional’, practice head Santiago Chacón has approaching 20 years’ experience and, having previously been at both PwC and EY, a strong international profile. Key support comes from ‘knowledgeable’ senior associates Ariana Martínez and Alejandro Gordillo, who each, in turn, have over 10 years in the sector. Recent matters include tax due diligence on behalf of Fosun International regarding a possible share acquisition; tax assistance to Valgardena Investments regarding real estate divestments; tax advice to Huawei with regard to the operations of its support centre in Mexico; and tax planning for the corporate reorganisation of the Mexican subsidiaries of aerospace group Aernnova. Other matters include tax planning for a JV, and transactional tax due diligence; and other clients include Iberdrola, Rolls Royce, Initec, Construcciones y Auxiliar de Ferrocarril and Atento.

With the 2015 arrival of ‘well respected practitioner’ Edgar Klee, as a partner, and the subsequent hire of experienced senior associate Mauricio Reynoso, Haynes and Boone, L.L.P. has established the core of a very capable tax team. Recent headline work saw Klee advise on the tax aspects of the firm’s representation of a group of leading Mexican institutional investors on their $2.1bn infrastructure investment JV (via a CKD) with Canadian pension fund manager CDPQ. Transactional matters are a staple and current work includes the tax aspects of Grupo Mabe’s $338m sale to Ontex. The three-strong team also has considerable work in the offshore and maritime services subsectors. Other matters include corporate restructures, litigation for the recovery of VAT overpayments; administrative challenges to tax assessments and tax advisory regarding finance facilities.

Nader, Hayaux y Goebel, SC established its tax practice in January 2015 with the hire of the Chevez-trained Adalberto Valadez. While full stand-alone capability is planned, the practice is currently focused on advisory and planning matters (it does not undertake litigation or transfer pricing), and in practice has a strong focus on corporate transactional and financial matters (particularly CKDs, ETFs and FIBRAs). Since his arrival, the firm has also hired a number of tax-specialised associates and accountant Mónica Pérez, who is fully dedicated to the sector. Recent matters saw the team act as tax counsel to DILA Capital and Banyan Tree Capital on the definition of tax efficient structures for their respective private equity funds, which will be incorporated as Mexican trusts; and participate in the structuring of the sale of GE’s sale of its Mexican real estate assets to Blackstone. Other matters included advising Prana Capital and Artha Capital on the structure of their respective third and fourth CKD funds, catering to a dual or two-tier investor profile within a single corporate governance framework. The team’s clients also include BlackRock.

Working across the tax (including transfer pricing) and international trade sectors, 11-strong boutique Natera, S.C. incorporates both accountants and lawyers. Co-founding partner Christian Natera leads the seven-lawyer team; dividing his practice precisely between tax consultancy and trade matters, he has ‘enormous knowledge on the tax aspects of commercial trade’. A strong second-line includes associates David Ramos and Karla P Flores on the tax consultancy side, and Patricia López Padilla who arrived in early 2015 to strengthen the fiscal litigation practice.

Six-strong tax and international trade boutique Ortiz, Hernández y Orendain, S.C. was established in 2014/5 by a group of senior tax and IT&C professionals that left Basham, Ringe y Correa, S.C.. Key tax-side partner Luis Ortiz has ‘enormous prestige’ and is hailed as ‘one of the most talented practitioners in the market’ and ‘an outstanding tax attorney’. His fellow founding partners Gerardo Hernández R and Ignacio Orendain manage the international trade and contentious aspects of the firm’s caseload.

The arrival of tax specialist Guillermo Aguayo from Santamarina y Steta has seen White & Case S.C. establish a solid tax capability in its Mexico City office. In particular, the capacity and synergies produced by Aguayo’s primarily consultancy focused practice in conjunction with the tax and administrative litigation practice of Ismael Reyes Retana have been notable. The team has already established a considerable client list to which it provides on-going tax advice, including -for example- Kansas City Southern, for which it has recently undertaken litigation to challenge VAT assessments, and the defence of a private ruling (obtained from the SAT in 2008), which the tax authority itself sought to challenge. Other matters include the structuring of inter-company transactions; tax-efficient structures for financial operations; risk assessment and cost-benefit analysis for proposed corporate reorganisations; and the structuring of a cross border JV. The practice also has particular expertise in tax matters relating to the electricity and oil & gas sectors and the impact of recent governmental reforms. Also noted is key associate Juan Ignacio Lopez, who focuses on international taxation.

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  • Notorious Marks

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