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Being ‘always an important market participant’, Chévez, Ruiz, Zamarripa y Cía SC is ‘forever a point of reference’ and ‘everyone’s competitor’. Founded as an accountancy firm 35 years ago, the firm has offered legal tax services for over twenty years, and has long been the dominant player in the sector with some 400 professionals – 200 of whom are lawyers – and unparalleled depth in its core areas of legal tax consulting and litigation, transfer pricing, social security related tax-matters, and international trade. The firm has lost a number of lawyers (most recently Juan Pablo Lemmen who moved to Ernst & Young in July 2016) during the ‘considerable re-shaping of the market’ occasioned by the move of major corporate law firm’s into the tax sector. However it reacted purposefully during 2016, naming three new partners in Monterrey and one each in both Mexico City and Querétaro, as well as hiring Armando Lara, formerly the Director General for International Treaties at the Ministry of Finance (SHCP). As a result, while it may have lost participation in certain market subsectors (capital markets deals, for example), the firm maintains its strong position with domestic Mexican clients, particularly in the financial services, real estate and retail sectors. It remains active in restructuring, for example, where its recent tax counsel mandates included advising Palace Resort and Grupo Edme in their respective out-of-court restructurings; and also in real estate, where recent matters included advising CIM Group on its MXN$4.2bn acquisition of six residential towers; and advising both buyer and seller in O’Connor Capital Partners MXN$133m sale of its equity interest in Centro San Miguel to affiliates of Consorcio ARA. The firm’s legal offering is divided into consultancy and litigation departments. On the consultancy side, key individuals among the ‘vast team’ include: Ricardo Rendon, who originated the firm’s transfer pricing department and is currently focused on international work and matters such as BEPS; René Meza and young partner Raul Navarro Becerra are noted for tax planning; (non-lawyer) Samy Lazarov is highlighted for wealth management and estate planning; the above mentioned Lara is also noted for international matters and treaty–related work; and New York office managing partner Eduardo Valenzuela has expertise in real estate and M&A transactions, the finance and energy sectors, and also leads the firm’s FATCA and CRS practices. On the contentious side, managing partner Manuel Sainz is hailed as ‘doyen of the practice’ and a ‘brilliant litigator’. Other figures of note include Ricardo Cervantes and Alejandro Torres, both of whom, like Sainz, have over 25 years’ experience; Querétaro-office managing partner Eudenio Franzoni, Monterrey-office managing partner César G Meraz, and younger partners Pablo Corvera (particularly for financial matters), César de la Parra and Daniel de la Parra, who also leads the firm’s anti-money laundering practice. As peers acknowledge, ‘Chévez is very capable’ and it ‘undoubtedly remains the leading firm for tax’.

A ‘sizeable specialist boutiqueTuranzas, Bravo & Ambrosi broke new ground over the last year, on the one hand becoming the Mexican member of the WTS Global alliance, which focuses on tax and legal consulting; and on the other making its first-ever lateral partner hire, which saw Carl E Koller arrive from what is now Deloitte Legal Mexico. The ‘brilliant and highly knowledgeable’ Koller has over 20 years’ tax experience (he spent some 15 years at Despacho Parás), undertakes both consultancy and litigation, and has experience across a broad array of industry sectors, including financial services. The firm is regarded as ‘very good indeed’, and the four founding partners as ‘technically brilliant’. A ‘very reliable individual’ and ‘a fine tax lawyer’, Mauricio Bravo undertakes corporate, indirect, and both local and international taxation, as well as individual wealth management and estate planning. 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. Angel J Turanzas has deep involvement in the direct sales sector (where the firm has a strong presence), handles oil-and-gas matters, and also ‘knows his stuff’ regarding inheritance. Primarily engaged in private client and wealth management matters, (but also handling corporate tax), Pedro Ramírez is for some ‘the best lawyer at the firm’ and is ‘very discreet’ and ‘technically splendid’. Younger partner Francisco Ortega is specialised in corporate tax and international taxation, and also undertakes the representation of clients before the tax authorities; while both Jorge A Cabello and Jorge Fuentes focus on tax litigation and representation before the SAT in the insurance and transport, and banking, pharma, retail and steel industries, respectively; Fuentes made partner in 2016. Recent matters saw Bravo lead advice to GT Global on the integration and separation of several businesses, a process geared towards tax consolidation; and Ambrosi act for long-time client Pernod Ricard on the group’s (local) restructuring; he also obtained a landmark decision on the clients behalf related to the taxation of assets. Turanzas advised Halliburton on the development of a structure to monetize pending credits with the public sector; Ortega advised Noble on the revaluation of recoverable tax credits, along with an administrative and litigation strategy to recover said amounts; and Ramirez advised Truper on the development of a structure ensuring income tax, IVA (VAT) and import duties optimisation. Senior associate Martha Ruelas is also noted; ‘brilliant regarding institutional relations’, she also ‘has real technical capability’. Clients include Grupo Gentera, Liverpool, Avon, Banorte, Dupont, Pinfra, Smurfit Kappa, Blue Marine, Pico Petroleum Industries, UBS, Credit Suisse, JP Morgan and Walmart.

A ‘very competitive’ proposition, Arias, Meurinne y Rodríguez, S.C. has had plenty to celebrate on its tenth anniversary as recent market turbulence has seen it gain clients. The 18-strong boutique works across the sector (bar transfer pricing) but is probably best known for complex litigation; contentious matters constituting some 75% of the firm’s workload. ‘We regard him as very relevant’ say peers of ‘great litigator’ Pedro Arias, whose practice includes constitutional amparos, and also reaches into the administrative field. His fellow name partner, Humberto Rodríguez and Salvador González Escamilla bring further senior expertise to the contentious team; the pair are ‘formidable’. ‘Dedicated figure’ Luis Eduardo Meurinne has a broader practice that takes in consultancy, auditing and litigation, but he is most in demand for his expertise in tax efficiency matters, where he is increasingly the “go-to” figure. All three name partners are also involved in the niche specialization of anti-money laundering in relation to tax. Peers’ respect is mirrored by the approbation of clients who note ‘fine, hands on service’, ‘deep knowledge and clear thinking’, and ‘genuine 24/7 availability’. A ‘knowledgeable and solid’ second tier includes junior partner Pamela Orozco and senior associates Elizabeth Lastra and David Salguero (each have over 12 years’ experience); and Leah Sánchez, formerly at the tax prosecutors office, who is identified as ‘a brilliant prospect’.

Differentiated by its ‘genuinely national coverage’ (the 70-strong practice operates from five offices), Baker McKenzie S.C. demonstrates a ‘good understanding and handling of technical aspects’ along with ‘excellent management and follow up’. Advising on the full spectrum of tax matters, the team acts for a primarily foreign clientele who appreciate the firm’s one-stop capability and the fact that ‘its lawyers are both local experts and plugged-in to an international network that ensures they are right up to date’. It is, however, the practice group’s profound capability in transfer-pricing matters that is a major differentiator from the majority of other firms. The Mexico City office includes the head of the firm’s regional transfer-pricing practice Moisés Curiel who has ‘enormous expertise’ (and can draw on the support of the firm's principal economist, TP-specialist Carlos Linares), as well as Roberto Cardona who is ‘top tier in the tax litigation area’. The ‘active’ Jorge Narváez Hasfura is chair of the firm's Latin America Value Added Tax practice group, and is also a member of the Global Value Added Tax steering committee; his recent matters include assisting Ensco Drilling on the SAT’s decision to disallow income deductions for intercompany services’ expenses; resolved before PRODECON, the team achieved a 90% reduction in the liability. Narváez and Linares also teamed up to advise Adidas de México on a further transfer pricing-related denial-of-deduction case, valued at $20m. Also highlighted is head-of-team Luis Carbajo, ‘an all-round international tax professional’ who focuses on complex issues in the energy sector; his recent work includes advising KBR on a major tax liability and associated out-of-court settlement; and Lear Corporation on a large tax inspection and assessment, administrative challenges and a local, post-acquisition corporate restructure. Other key figures in the sizeable group include Héctor Reyes, who also has extensive experience of international tax planning, M&A and cross-border transactions, and intercompany pricing; and Ulises Castilla, a former head of contentious matters at the SAT’s department for major contributors who has over 20 years’ experience advising on tax strategy (he also undertakes litigation). Other clients include PKC Group, Anadarko, KBR, Damen Shipyards, WR Grace & Co., and WestRock Company. The firm also hired the very experienced Rocío Perez-Nava, as a senior associate, from the SAT; she also has extensive experience as an in house at Televisa. Since research concluded, tax planning and advisory practitioner Ronaldo Moya has left the firm.

The leader on mining sector-tax matters ‘from Peñoles to GoldcorpBasham, Ringe y Correa, S.C. fields a 26-strong practice which offers a full range of tax services. Long best known for its litigious capability, over the last few years the department has re-oriented its practice towards preventative issues, tax planning and transactional tax matters, while more recently, the firm’s transfer pricing group has also been strengthened with the addition of an ex-SAT accountant. The department’s stellar corporate client list includes the likes of, Minera Peñasquito, Desarrollos Mineros San Luis, Coca Cola Export, Colgate-Palmolive, Aerovías de México, Sumitomo and Volkswagen, which it serves from offices in Monterrey, Querétaro and Mexico City. Senior practice partners Gerardo Nieto (consulting, litigation, audits, restructuring and planning), Gil Zenteno (complex tax litigation), and Alejandro Barrera (head of tax consulting, planning and strategy) all have over 25 years’ experience in fiscal matters; and further strength comes from Victor Barajas and Mario Barrera, whose primary specialisations are wealth management and transfer pricing, respectively. As a whole the team is reported as ‘alert to opportunities’, ‘efficient, technically sound’ and service oriented. Recent matters include successful constitutional proceedings (amparos) against new mining fees introduced in 2014; advising a mining sector player on the preparation of a tax-efficient sales strategy in which withholding tax matters were critical; and British Columbia Investment Management on a corporate reorganization to ensure the retention of its exempt status. Monterrey-based senior associate Luis Alejandro Casarín, whose tax practice reaches in to patrimonial matters; and experienced associate Sergio Arrellanes G, are also noted. Other matters include contesting a multimillion-dollar tax liability resulting from an SAT change of criteria; the contesting of the ruling-out of transfer pricing-derived deductions; and matters related to direct sales.

Now with ‘four great partners’ that constitute ‘a great mix of talent’, the ‘aggressiveCreel, García-Cuéllar, Aiza y Enríquez, S.C. has ‘set the bar really high’ and is ‘gaining important market penetration’, most notably ‘for financial M&A and tax related matters; peers now regard it as ‘very much a relevant team in consultancy matters’. Clients go further, calling it ‘the best option’, adding that ‘value for money is okay’. The 26-strong team is ‘very knowledgeable and responsive’ and ‘communicates clearly’, demonstrates ‘perfect industry knowledge’ and ‘prepares strong legal arguments to defend’ clients’ positions. ‘Simply outstanding’, practice head Alejandro Santoyo (ex-JP Morgan) is an accountant and a lawyer; his recent headline mandates include acting as lead counsel to FIBRA Macquarie on it $685m refinancing (with support from counsel Ericka González); and leading advise to Riverstone Capital on its MXN$12.5bn CKD issuance, involving the development of a complex, one-of-a-kind carried-interest structure. A former assistant deputy commissioner at the SAT and OECD consultant, the ‘very competent’ Jorge Correa has deep public sector knowledge as well as both financial and energy sector expertise. In recent headline work he led the team advising Pinfra on the emblematic $623m Fibra-E issue, a first-of-its-kind transaction with an instrument distinct precisely as a result of the tax transparency of the underlying entities. Correa and Santoyo also teamed up to advise First Reserve and Kohlberg Kravis Roberts (KKR) on their respective $700m and $1.27bn sale-and-leaseback transactions with Pemex, the tax aspects included structuring the offshore and on-shore investments, reviewing the financial model, negotiating and executing the transaction, and supporting the set-up and continuous operation of the SPV. In both cases the team is also representing the SPV on the VAT refund generated by the purchases. The very good Omar Zuniga is ‘a recognised individual in the world of international tax law’; he and newly appointed counsel Eduardo Michán advised the Vontobel family on the Mexican tax implications of the transfer of its Vonpar shares to Coca Cola FEMSA, along with an additional, associated equity-investment. Zuniga also acted as tax counsel to Bristol Myers Squibb on a $160m pharmaceutical trade mark transfer. In addition to its outstanding transactional tax work, the practice is also very active in day-to-day advisory and preventative work. For example, new partner Luis Vazquez, with assistance from senior associate Diego Garza, advised Mitsui and Samsung joint venture Terminal KMS de GNL on a $45m tax audit liability arising from a SAT challenge to deductible expenses; the matter was resolved successfully at the administrative appeal stage. The two provide ‘very good service’; and the ‘very knowledgeable’ Vazquez, a litigation and tax controversy specialist, is ‘straight forward in his analysis and comments’. In May the firm announced the hire of accountant Laura Frias, as counsel, (along with team of specialised associates) and the launch of its new transfer pricing practice. Frias is a former head of transfer pricing at General Electric and was also manager of tax planning at Televisa. Other moves saw senior associate Nadja D Ruiz return to the SAT before moving to Ernst & Young; while associate Eduardo Brandt arrived from the same consultancy group.

Undoubtedly the strongest of the “Big-4” consultancies in Mexico, the ‘increasingly strong’, Ernst & Younghas good market penetration’ and is a noted competitor in the international tax and tax disputes areas in particular. 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 international tax services Koen van’t Hek is also recommended; he 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, Head of tax controversy Enrique Ramírez Figueroa is highly regarded and a ‘brilliant litigator’; he and fellow contentious partner Nora Morales ‘do a very good job’; Morales focuses primarily on transfer pricing and tax treaty matters, particularly in relation to financial institutions. Jorge Libreros and Manuel González are also noted. Head of private clients’ services, Elias Adam Bitar is ‘an impressive attorney’: his practice also has a strong international tax component, particularly in relation to the technology sector, energy, real estate and financial services. Covering oil & gas, power, utilities and mining, Alfredo Alvarez is head of the energy segment for Mexico and Central America; in a recent highlight, he and his team worked on the norms underlying the new FIBRA-E energy-and-infrastructure investment trust instrument. However, the practice lost Houston-based energy-sector specialist Oscar López Velarde who left to co-found the tax practice at corporate mainstay Ritch Mueller, Heather y Nicolau, SC. Despite this loss, the firm continued to reinforce its bench and further to the February 2016 incorporation of Rocio Gonzalez Alcantara as head of regulatory matters, made the ‘notable hire’ of Antonio del Campo who arrived from a position as head of contentious matters for major contributors at the SAT in August; he had previously spent a decade at Chévez, Ruiz, Zamarripa y Cía SC. Additionally, Nadja D Ruiz arrived as a partner after a lengthy period at the SAT – primarily in the department of international norms, and, most recently, as head of Mexico’s implementation of FATCA and CRS. On the corporate side, where the firm has had a notable capability since its 2015 incorporation of the Forastieri y Roqueñí firm, the firm hired former Baker McKenzie S.C. Guadalajara office-manager, Jose Zozayacorrea, as head of legal for Central – West México. Former tax manager Eduardo Brandt moved to Creel, García-Cuéllar, Aiza y Enríquez, S.C..

A ‘very good boutique indeed’, the 17-strong González Luna, Moreno y Armida is ‘definitely regarded as a competitor – particularly for litigation’ by peers who note the firm ‘has a real presence, particularly in niches such as FIBRA-related work’. With over 20 years in the market, the firm 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, ‘very good tax lawyer and negotiator’, Ramiro González Luna is ‘a fantastic professional – great on advisory, transactional matters, monetization matters: he does it all very well’; ‘it’s a great experience to work with him’. He focuses on tax advice and consultancy, particularly as regards corporate and international tax matters, and 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); past 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. Senior associates Fernanda Estrada and Cristina De la Torre are also noted, and associate Luis Carlos Moreno is also part of a very capable second line. Sofía de la Fuente moved in house as VP for legal obligations at JP Morgan. Key clients include Evermore. As of late August 2017, the firm has announced its integration into DLA Piper Gallástegui y Lozano.

Primarily oriented towards consultancy, which constitutes some 70% of its caseload, Jáuregui y Del Valle, S.C. has consolidated a presence in the funds sector with a steady flow of structuring mandates. The team also has a significant wealth planning practice, and while its advisory work has an emphasis on ease of tax recuperation, the practice also undertakes fiscal litigation if necessary. ‘A great lawyer and “fiscalista”’, practice head Luis Gerardo Del Valle Torres has ‘a forthright style’ and is ‘very capable’; recent work saw him advise Grupo Turin on a tax efficient structure for the $175m sale of its shares to Mars, and PGIM Real Estate vehicle PLA Industrial Fund I in a $30m tax litigation concerning a VAT tax assessment. In conjunction with Eduardo Medina Zapata he also advised PGIM on the restructuring of its for-lease multifamily platform, and on its $250m sale. The ‘active’ and ‘increasingly visible’ Medina acted as tax counsel to Walton Street México CKD Managers II and PLA Administradora IV on the structuring of its $375m and $290m issuances; and in a further PGIM mandate, advised on its acquisition of the shares of FRBC Arrendadora Monterrey, and the structuring and tax provisions of the SPA – a matter made more complex by the tax structure of the private equity fund seller. The team also advised on the tax structure, and the negotiation of the tax provisions of the asset purchase agreement, for Finsa CD II’s $87m acquisition of a large portfolio of industrial properties; Corporate Properties of the Americas (CPA) on the restructuring of its Calzada Capital fund, involving a complex cross border corporate reorganization; and Clarion Partners’ Lion Mexico Fund on the restructuring of part of its debt platform. Significant FIBRA sub-sector work included advising FIBRA Terrafina on the tax structures for the acquisitions of the $480m ‘Scorpion’ industrial portfolio (a deal under negotiation for more than a year), and a smaller $80m industrial portfolio. Other matters include challenging a determined tax credit, revocation appeals, and advice to a state entity. The team can also call on senior counsel Luis Carballo Balvanera who focuses on transactional tax matters and tax litigation; and, after the departure of the associate-in-charge, the firm hired accountant Adrián Vallejo from PricewaterhouseCoopers, SC to reinforce its transfer pricing practice. Associate Ricardo David García Robles is also noted. Clients include American Industries, Southern Cross and CKD Planigrupo.

Establishing a tax practice back in 2011, one of the first corporate firms to do so, Jones Day’s four-strong Mexican tax group is distinct in so far as a significant proportion of its work is derived from the firm’s global network, giving it a strongly international orientation. Tax planning and transactional matters constitute the weight of the caseload but the practice also undertakes tax audits and relevant administrative and regulatory issues. Practice head Rodrigo Gómez undertakes both tax consultancy (including planning and advisory), and tax litigation, as well as international trade and customs work. Key support comes from associates Luis Rodrigo Salinas and Andrés Lieja; Salinas focuses primarily on transactional work and consulting, while Lieja has particular expertise in PRODECON’s “conclusive agreements” process. Headline mandates saw the team advise a major automotive company on the Mexican tax consequences of the tax incentives granted by local government for establishing a new $900m plant in Mexico; and Toyota Motors (as part of a joint venture with Mazda), on the tax aspects of a possible $150m investment. In litigious matters the team is representing the Mexican subsidiary of a retail entity on a $10m tax treaty interpretation case against a SAT tax assessment (as well as advising on two tax audits and a VAT refund); and a US construction firm in two litigations against a tax assessment by the Mexican Social Security Institute (IMSS). In the maquiladora subsector it is advising an international manufacturer on an $18m domestic advance pricing agreement request with the Mexican tax authorities. Clients include American Standard (Lixil Corporation), Lowe’s Corporation, GIC Real Estate, Shiloh Industries, Essilor International, Forbes Energy Services Patron Spirits and FINCA Microfinance.

In march 2014 the then Ortiz, Sosa, Ysusi, entered into an association with KPMG, an arrangement that lasted two years before the firm opted to revert to its independent status, returning to the market as Ortiz, Sosa Y Asociados, S.C. in 2016. Originally founded in 2001, the 16-strong boutique had earned a stellar reputation prior to its entry into KPMG; initial signs suggest it has lost little, if any of its capability, with peers considering the ‘visible’ team as ‘very good’, ‘true competition’ and as ‘likely to make its mark’. The practice handles a caseload predominantly composed of planning and preventative work but which also includes a significant contentious component. Primarily composed of accountants, including the Miguel Ortiz (‘reliable, honest – a great tax practitioner’) and Ignacio Sosa (‘among the best’), who both have ‘great reputations’; on the legal side, however, the key figure is Luis Curiel, a ‘sharp, capable and efficient lawyer’ who ‘knows his way round the tax area’; and the ‘highly experienced’’ José Manuel Trueba, who was a legal advisor to tax authority SAT prior to his arrival at the firm in 2008. Recent matters saw the team assist companies in diverse sectors, such as construction and pharmaceuticals, obtain significant reductions of their respective multihundred-million peso tax credits (as determined by SAT tax audits). It has also assisted clients with ‘Acuerdos Conclusivos’ (Final Agreements) via the PRODECON tax dispute resolution mechanism. Curiel and Trueba are supported by ‘very proficient seniors’ Eduardo F Lalieu and Fernando Gomez Mazin, who both handle procedural matters.

PricewaterhouseCoopers, SC’s Mexican operation continues to consolidate its position amidst the turbulence of the tax sector. Following notable 2015 hires, including both former Ernst & Young transfer-pricing practice head Jorge Castellon Velarde and ex-OSY founding partner Jesús Francisco Morales, who arrived as managing partner, in June 2016 the team has added former Chévez, Ruiz, Zamarripa y Cía SC senior associate José Ricardo Soto as director of its administrative litigation practice. The firm houses considerable talent and experience in its network of 20 local offices across the Republic, ‘first-and-foremost’, head of legal and ‘cornerstone of the firm’s local legal practice’, Eduardo Méndez Vital who has over 30 years’ experience in consulting and litigation matters. Key figures Sandro Castañeda and Raúl Bolaños V have over 25 years’ experience each; both undertake 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 matters have seen the firm particularly active in the mining and renewable energy sectors, and it also participated in the $2.5bn acquisition of Coca Cola Texas’ bottling operations by Arca Continental. Also noted are senior associates Cynthia Angélica Covarrubias - Alberto Diaz de Leon and Juan Manuel Perez. Past 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.

A unique firm – it has offices in Calgary, Dallas, Mexico City and Bogotá – SMPS Legal has ‘has grown very quickly’ and ‘positioned itself strongly’. While the firm has amicably concluded its alliance with the well-known Manuel Tron, with whom the team continues to share a number of clients, it has not forfeited its visibility in the sector. Tax has been a central pillar of the firm since its founding, with practice head Jorge San Martin (who is both an accountant and a lawyer), described as ‘a very solid and capable practitioner’. He is seconded by Ana Paula Pardo, formerly of Hogan Lovells BSTL, S.C., who has an international tax focus; ‘really effective’ tax-litigation specialist Christian Solis; and senior associate Federico Scheffler, who has a strong focus on advisory work, primarily in relation to M&A transactions and restructuring. The 11-strong team is full service in tax matters (barring transfer pricing) and has a ‘splendid litigation ability’; and the firm’s unique geographical footprint has resulted in a strong engagement with the energy, mining and oil & gas industries, in particular – 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 advising Grupo Axo on the tax aspects of its implementation of a joint venture with US-company PVH via merger with its Mexican subsidiary, Baseco; and T69 on the structuring the $133m financing of a multipurpose building on the Paseo de la Reforma, Mexico City, including the incorporation of a private FIBRA. Other work included advising various clients on the tax aspects of transactional mandates, tax advice and preparation of trust agreements, patrimonial matters, and tax audit and PRODECON resolution processes.

The ‘very solid and reliableSánchez Devanny continues to act ‘effectively’ across the breadth of the tax sector (bar transfer pricing). With the January 2017 election of Mariana Eguiarte to the partnership, the 16-strong team now includes four partners and an additional, dedicated of counsel. Headline mandates saw a team led by Monterrey-based practice head Ricardo León Santacruz – and comprising Eguiarte (of whom peers ‘have a very good impression, particularly for structuring matters in transactional work’), tax of counsel José Ángel Eseverri, and senior associate Jorge López – act as lead tax counsel to Arca Continental on its $2.5bn acquisition of Coca Cola Texas’ bottling operations. León Santcruz is ‘a very proficient tax practitioner’ who ‘leaves no stone unturned in the search for adequate results for his clients’. Other matters included assisting clients with the reduction of tax liabilities, particularly in relation to transfer pricing methodologies; tax investigations, audits and assessments; VAT certifications (particularly in relation to the maquiladora sector), PRODECON procedures and “amparos” (constitutional injunctions); and tax-driven restructurings. Other key figures include Guillermo Villaseñor in Mexico City, a ‘well known’ and ‘respected’ tax counsel, his practice has a strong energy-sector aspect and he is also committee chair for legal and tax affairs of the Canadian-Mexico Chamber of Commerce; and the dual qualified (Mexico/California) Abel Mejia in Querétaro, whose practice also covers private wealth management and estate planning. Mejía recently counselled Banque Pictet on the legal and tax aspects of potential Mexican operations; and advised UBS on tax compliance protocols for its Mexican clientele. The team is highlighted for ‘solid client service skills’ and its ‘technical facility’; and corporate partner Humberto Morales is also noted for compliance and regulatory matters. Clients include Nissan, Dr August Oetker, H&M Hennes Mauritz, Eaton Corporation, FEMSA-KOF, Grupo Vise, Hewlett Packard, Libbey, Clariant and Publicis.

Clients are ‘very pleased’ with the service levels at Gardere, Arena y Asociados S.C., noting ‘first class work’, albeit ‘a bit expensive’, ‘a very good level of industry knowledge and the applicable regulations’; overall they ‘highly recommend the firm’. The Mexican office of Gardere Wynne Sewell LLP, clients also highlight the firm’s ‘bi-national expertise and sensibility’ and ‘strong business orientation’. The five-strong practice group is co-led by Fernando Camarena (‘smart, technically strong, energetic, passionate and helpful – not to mention timely’, he ‘provides excellent all-round service’); and office managing partner Roberto Arena who has ‘profound expertise and knowledge of the subject matter’ and whose ability to ‘summarize and present issues is outstanding’. The two frequently work in tandem and in recent headline litigation matters represented Herbalife in a constitutional challenge to a new 8% tax levied on high-calorie foods, which it also successfully challenged in the tax courts, obtaining a definitive – and precedent setting – resolution in its client’s favour. Other matters saw the pair advise games technology company, IGT (formerly Gtech), on the tax structure for its Mexican operations; home appliance manufacturer, Whirlpool, on a tax contingency that threatened its 0%-VAT rating for exports; MTS Sistemas Solares on the tax aspects of an insurance claim stemming from hurricane damage to one of the client’s plants; and automotive solutions group Faurecia on tax planning for its employees in Mexico. Other key members of the team include specialised tax associate Aldo Mendoza, who focuses on local in international tax litigation and “amparos”; and Maria Fernanda Mateospayro, whose practice has more of a corporate aspect, and includes domestic tax matters and tax counselling, along with administrative litigation. Other matters included the analysis of bi-national, parent/subsidiary tax structures, and complex tax litigation. Clients include Brightstar, Ford Credit de Mexico, Littelfuse, Peugeot Finance Mexico, Tesco and Refigure.

Spanish powerhouse Garrigues has long been known for its strength in tax matters and it should come as no surprise that the firm’s Mexican office fields a team that, while small, is ‘highly impressive’ and ‘punches above its weight’. The six-strong team, comprising four lawyers and two accountants, houses considerable expertise across both consultancy and (administrative) litigation, and has also been active in transactional work and structuring in particular, along with planning and advisory matters. Certainly ‘it appears to be increasing its market penetration’. ‘Great professional’ and ‘a really knowledgeable lawyer’, practice head Santiago Chacón has approaching 20 years’ experience and – having worked in both London and São Paulo, and at both PwC and EY – ‘has a genuinely international perspective and understanding’, as well as a strong international profile. Recent key matters include advising Telefónica on tax planning for the restructuring of its Mexican subsidiaries, including an asset carve-out; Celestics Holdings on the submission of an appeal against a transfer pricing assessment; and Bankia on the tax aspects of a MXN$61m divestment of shares in a Mexican housing finance entity. Chacón leads on all matters but can draw on support from senior associate Ariana Martínez (an accountant), and Alejandro Gordillo, who focus on tax advisory and compliance, and tax advisory and contentious tax matters, respectively; each has over 10 years in the sector and ‘form a great team’ that ‘knows its stuff’. Additional mandates include advising IFC on tax matters related to several financings by the group for real estate projects; fashion retailer Grupo Cortefiel on the tax aspects of a due diligence process on its Mexican subsidiaries (within the framework of a potential IPO of the Spanish holding company); and Total on an internal review of some uncertain tax positions. Other matters included tax due diligence, tax advisory on the repatriation of profits, tax structuring, VAT verifications and refunds. Practice clients include JC Decaux, Iberdrola Inmobiliaria, Zurich Santander, OHL, Aeronova, Atento, Globalvia, Barclays and LafargeHolcim.

Hogan Lovells BSTL, S.C.’s 2016 hire of Jaime Espinosa de los Monteros from Muñoz Manzo y Ocampo, SC has continued the redevelopment of the office’s tax practice and builds upon the earlier return of Arturo Tiburcio; the firm’s mid-term intention is to develop a fully-fledged stand-alone practice. Mexico City-based practice head Tiburcio is ‘deeply experienced’ and has a strong (though not exclusive) focus on contentious matters; he is supported by ‘able right hand man’, senior associate Franciso Pamero, who works across tax consultancy, audit procedures, tax treaties, and tax and constitutional litigation. In Monterrey, where Espinosa is ‘established’ and ‘well known’ (he opened Basham, Ringe y Correa, S.C.’s office in the city back in the early 2000s), support comes from senior associate Maria Teresa Garza Lozano, who handles tax advisory, tax litigation, and administrative matters. The 11-strong practice group’s recent workload includes mandates concerning VAT as related to royalty agreements; representing clients in audit procedures, nullity trials and “amparos” (constitutional injunctions); and tax and business structure analysis (particularly in relation to the BEPS criteria adopted by Mexico); the practice has also seen a steady flow of litigious mandates as Mexico’s tax administration service, SAT, has adopted more stringent criteria, particularly in relation to tax deductibles in transfer pricing agreements. Representative clients include: Lufthansa, Schlumberger, Conservas La Costeña, ESPN, Banco Invex, The Walt Disney Company, Grupo Aeroportuarios Centro Norte and Caterpillar.

Long highly reputed, the former Ortiz, Sainz y Erreguerena, now Ortiz Abogados Tributarios S.C. remains in a process of restructuring following the departures of José Miguel Erreguerena to Rizo, Erreguerena y Garza-Cantú, S.C., and Arturo Pérez Robles, Gabriela Pellón and junior partner Denise Lester to Galicia Abogados SC 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’. A former president of the Mexican bar association (2013-15), ‘brilliant’ name partner Gabriel Ortiz is ‘a trade mark in the sector’ and is ‘held in the highest regard’; ‘an excellent lawyer’, he is best known for his ‘remarkable, genuinely outstanding litigation skills’, although 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). New associate hire Pablo Escalante, arrived from Ernst & Young in mid-2016; and the firm also saw the return of Pablo Ramirez Morales, who had moved in-house at ArcelorMittal in mid-2015.

Being ‘technically very strongRizo, Erreguerena y Garza-Cantú, S.C. is a small, six-strong boutique, originally founded in 2013. All three name partners, Juan Carlos Rizo, Carlos Garza and Jose Miguel Erreguerena, (who arrived from OSE in early 2016), have ‘great reputations’ and over 20 years’ practice experience. The firm’s workload is split more or less 50/50 between consultancy and contentious matters, although the make-up of the contentious portion has shifted radically towards PRODECON negotiated settlements at the expense of litigation. Overall the firm finds itself receiving far fewer day-to-day and compliance related matters, and far more sophisticated and complex mandates, along with a steady flow of tax-related restructuring work and, increasingly, consultations regarding tax efficiency. Founding partners Rizo and Garza both spent over ten years at Mexico’s tax authority, SAT, the former undertaking contentious matters (litigation and amparos), while the latter was more involved with tax norms, both domestic and international. Erreguerena’s arrival has ‘undoubtedly boosted the firm’s market profile’ and, after almost twenty years at what was formerly ‘OSE’ (now Ortiz Abogados Tributarios S.C.), he brings a first-class reputation for all aspects of consultancy work. Recent matters include successful litigation and PRODECON ‘conclusive agreement’ settlements, as well as extensive negotiations with the SAT regarding transfer pricing issues, particularly deductions; the team also has a number of significant cases with the Big-4.

The small, five-strong practice at the full-service Santamarina y Steta benefits not only from the firm’s corporate and transactional departments, but in particular from the strength of its top-flight bankruptcy practice, from which the tax team derives considerable advisory and (re-)structuring work. The core of the team is comprised of the ‘incredibly knowledgeable’ Mariano Calderón, who has over 20 years at the firm; senior tax counsel Agustín Gutiérrez, who can draw on three decades’ experience in the sector; and senior associate Karina Robledo who has 15 years exclusively focused on the sector, including five at PricewaterhouseCoopers, SC. Recent matters saw Calderón and Gutiérrez, in conjunction with bankruptcy partner Fernando del Castillo, counsel Abengoa on the tax implications (in Mexico) of its global restructuring plan; advise Hipotecaria Su Casita on the assessment of tax credits by the SAT within the context of the company’s bankruptcy procedure; and assist General Motors de México on various tax matters including advisory regarding transfer-pricing compliance and tax audits, and representation in tax litigation. Other matters include the filing of nullity claims and “amparos”; advisory on the tax consequences of the execution of collateral; the design, planning and implementation of tax structures; tax-led restructuring matters, and counsel on the new obligations related to electronic accountancy and transfer pricing operations.

Headline mandates at ‘full-service outlierVon Wobeser y Sierra, SC saw the team handle all tax matters related to BMW’s $1bn investment in a new luxury car factory located in San Luis Potosi; and Anheuser Busch InBev on the tax strategy for the acquisition of Cervecería Mexicana. ‘Eminent’ practice head Fernando Moreno is ‘a genuine senior figure in the tax arena’ and ‘really knowledgeable’; he has almost 30 years in the sector and his practice covers consulting, planning and litigation, with particular emphasis on treaty matters and tax minimization/efficiency. Key support comes from senior associate Jorge Diaz Carvajal, who focuses on tax, social security and international trade and customs (he too has a certain focus on treaty matters and the avoidance of double taxation. Further mandates include counsel to Knauf on the definition of its tax strategy in relation to the acquisition of mines in Mexico; Grupo Modelo with regard to the tax strategy for a $325m investment in a brewery pant and cannery in Yucatan; and Acqua Minerale San Benedetto on the tax aspects of the sale of its participation in various Mexican entities as part of a joint venture agreement with Peñafiel Aguas Minerales. In addition, the team receives a steady flow of litigious matters, a sub-sector where the firm has ‘considerable fire-power’ – most notably, head of litigation Marco Tulio Venegas. Other matters include counsel on tax analysis and efficiency matters, double tax agreements, and both transactional and non-transactional structuring work. Clients include Burger King, Horizon Global, Procter & Gamble, Cimentaciones Mexicanas and Robert Bosch.

A litigation capability in offices across nine cities distinguishes Deloitte Legal Mexico from its competitors. The firm has been looking to broaden and strengthen its high-end offering in transactional and advisory matters, most recently hiring Eduardo Revilla in September 2016. A former Director of Tax Policy Legal Affairs at Mexico’s Ministry of Finance, Assistant Federal Tax Attorney for Litigation and Director General of International Fiscal Affairs, Revilla also has private practice law firm experience. The core team includes international partner Laura Rodriguez Berron who has extensive experience of the Central American region as well as Mexico; and practice lead Eduardo Barron. Headline advisory matters saw Barrón, acting with support from Rodríguez Berron, counsel a private equity group on an $852m sale of a portfolio of Mexico-located wind farms. Contentious partners include Hugo Romero Cervantes in Mexico City, Raciel Flores Talavera in Guadalajara, and Gonzalo Mani de Ita and Carlos Alberto Ramirez in Monterrey. Recent contentious matters include Talavera’s representation of a major financial services entity in litigation against tax assessments involving price-transfer adjustments, the first of their type in the financial-real estate sector (aggregate value $27.5m); Mani de Ita represent Wipro Technologies in litigation against SAT tax credit determinations; and Romero represent the same client in successful Supreme Court litigation. Jorge Antonio Jimenez in Mexico City, and tax litigation directors Abel Camacho Brito (Querétaro), and Ricardo Santoyo Reyes (Mexico City) are also noted. However, highly reputed international partner Carl Edward Koller moved to Turanzos, Bravo + Ambrosi in mid-2017. Clients include Siemens, Eaton Corporation, Tenneco, Baxter, Calavo Growers and Vibracoustic.

The mid-2016 arrival of former “OSE”-partner, Gabriela Pellón and her ‘very good’ team at Galicia Abogados SC was a pivotal moment in the recent move by corporate law firms to develop significant tax capability, all but ensuring the phenomena would continue and broaden. The ‘very experienced and respected’ Pellón arrived with four other lawyers, including former OSE-junior partner, Denise Lester, and has since hired a further two lawyers; while the department certainly remains ‘a work in progress’, it is regarded as having ‘a solid foundation in place’. Pellón has a broad practice but is best known for her contentious tax work, hence the importance of the arrival of Arturo Pérez Robles as a counsel (although he also retains his own private practice). Pérez Robles has over 25 years’ in the sector and is ‘simply brilliant on planning and consultancy work’. Recent mandates include advising a client in the retail sector on the tax structure for a major real estate acquisition; advising a multinational conglomerate on relations with Mexico’s Tax Administration Service, and handling its audits; and tax efficient structures and tax-benefit maximization in the renewables sector. Certainly initial client responses to the practice have been favourable: ‘the level of service is excellent: response times are very good and opinions are very thorough and well-researched’, demonstrating ‘knowledge not only of tax law but of corporate and administrative aspects as well’; or again, ‘a first class team, it’s ‘really sophisticated and capable of dealing with complex matters’. Pellón not only ‘understands clients’ needs and how to organize the team for their benefit’, but also has ‘a deep understanding of business practices as applied to her area, therefore her advice is not only legally sound but also makes business sense’. Senior associate Lester and associate Gabryela Valencia are also noted. Other matters include VAT refunds, PRODECON procedures, audit processes, the litigation of tax assessments, “amparos”, and general tax advisory.

With ‘a price/quality relation that is one of the best you’ll find’, Nader, Hayaux y Goebel, SC is ‘a great firm on which to rely for novel operations and innovative structures’. The firm established its practice back in 2015 with the hire of Chevez-trained Adalberto Valadez, whom clients laud for his ‘profound knowledge of tax matters’, ‘ability to find simple solutions’ and ‘great disposition and availability as needed’. While the mid-term goal is full stand-alone capability, the practice is currently primarily focused on advisory and planning matters (it does not undertake litigation or transfer pricing) in relation to corporate transactional and financial matters, particularly the origination of unique trust structures in relation to instruments such as CKDs, ETFs and CerPIs, so as to facilitate investment. The firm has also hired a number of tax-specialised associates (notably, Paola Plaza) and a tax-dedicated accountant, Mónica Pérez, adding further capacity to the practice. Clients speak of ‘a very positive group’, that demonstrates ‘great willingness and creativity when it comes to resolving the tax issues put before them’. Recent mandates include acting as tax counsel to both DILA Capital and Banyan Tree on the tax efficient structuring of their respective private equity funds (these will subsequently be incorporated as trusts capable of accepting investment from regulated entities such as insurance companies or State-sponsored funds such as INADEM); Desarrollos Delta on the structuring and placement of MXN$800m of CKDs; EMX Capital on the most suitable structure for its acquisition of Consorcio Industrial Valsa; and Barclays Capital Casa de Bolsa on MIRA’s CerPI issuance, so as to ensure optimum tax treatment in a transactions involving an instrument that does not have an established tax regime under Mexican law. Practice clients include Artha Capital, BlackRock and General Electric.

With its January 2017 hire of two ‘very capable’ energy-focused tax partners (and their seven-strong team, which includes accountants) from Ernst & Young, Ritch, Mueller, Heather y Nicolau, S.C. became the most recent of Mexico’s full service corporate law firms to begin the process of developing a significant in-house tax capability. While sources comment that the team will have to ‘manage the learning curve of moving from a Big-4 consultancy environment to a law firm’ and ‘broaden out of just energy work’, it is also noted that ‘they have hit the ground running’ and are ‘already very active in windfarms, projects, oil and gas, and infrastructure’. Recent mandates saw practice head Oscar Lopez Velarde Pérez (‘a great lawyer despite his youth’), advise BHP Billiton on all tax aspects of the structuring of its $1.8bn joint venture with Pemex, regarding the farm-out, exploration and extraction activities for the Trion deep-water block; CENAGAS on its Mexican energy sector reform-mandated corporate restructuring; and Glencore on the structuring of the first-ever joint venture between an international petroleum trader and a group of gas stations (that will subsequently relinquish the Pemex franchise). His fellow partner, Santiago Llano Zapatero teamed-up with corporate-finance specialist Jorge Oria y Anaya to advise Canadian Solar on the structuring of its investments in Mexico as part of its participation in auctions for long-term clean energy production PPAs. While, given the recent inception of the practice, client feedback is limited, one enthused client noted: ‘yes for energy-related tax work – yes, already!’ Senior associate Juan José Paullada is also noted.

In the face of changing market requirements, White & Case S.C. has moved quickly to develop its tax capability over the last two years and today boasts an eight-strong team. Recent matters saw practice head Guillermo Aguayo lead tax advice to Treofan Mexico on its corporate reorganisation (as part of a global debt refinancing); and, in conjunction with former sub-procurador fiscal, Ismael Reyes-Retana, advise Kansas City Southern de Mexico (KCSM) on a range of tax issues, including defence against SAT tax audits and the tax aspects associated with a $2.1bn notes issue. Other work include advising clients on alleged tax shortfalls resulting from tax audits; the negotiation of conclusive agreements with the Federal Taxpayer Protection Agency (Prodecon); ongoing advice in relation to investigations by the federal tax authority, SAT; transactional tax matters and the tax aspects of corporate restructurings. The practice also has considerable experience on tax matters concerning financial institutions, their transactional operations and intercompany ISDA Agreements; and in the litigation of contentious tax matters with a constitutional aspect. Key associate Juan Ignacio Lopez is also noted.

Being ‘talented, efficient and with a human character that distinguishes it from competitors’, developing firm Acedo, Santamarina, S.C has eight years in the market and a broad service offering; it is probably best known for its telecoms practice. Nevertheless, the firm is gaining profile and market position in a number of other areas, among them, tax, where the seven strong team, led by Rafael Tena Castro, is ‘very highly trained, provides rapid responses to complex questions, is available at whatever hour and provides personalised, detail-oriented attention on all matters entrusted to it’. The group handles tax audits, local and international advisory, tax planning, and compliance (and private letter rulings), as well as contentious tax matters. Practice head Tena Castro, who made partner in early 2016, is ‘an expert in his field’ who ‘develops innovative solutions and ensures delivery within agreed timeframes’; moreover, ‘he grasps the importance to us of the transactions we undertake together’. Recent mandates involved nullity lawsuits against SAT assessments, constitutional “amparos” concerning VAT refunds, tax audits concerning certificates of origin, double taxation issues and legal opinions regarding deductibility. Clients include Pepsico, GAMESA, Eymsa Servicios, Fidelity Marketing, CMR, Ghenova Ingeniería, PRGX de México, BBC Worldwide and Vicrila Glass.

Understated’ but ‘providing very good counsel’, mid-sized corporate player Creel Abogados, SC counts the tax sector among its core practices and fields a five-strong team that practices across the full gamut of tax consultancy, tax litigation, transfer pricing and international trade matters. ‘Quietly effective’ practice head Carlos Martínez R focuses primarily on the tax aspects of M&A, capital markets and financing transactions; while his fellow partner Javier Portas, who has ‘encyclopaedic knowledge’ and can draw on more than 20 years’ experience in the sector, also undertakes transactional tax work but is principally focused on corporate reorganizations estate planning and tax litigation; as well as leading on international trade matters. Recent mandates include advising EFM Capital (and a number of individual shareholders) on the tax aspects and tax structure of the sale of 76% of Even Telecom to Southern Cross; RTA Mexico on a tax amnesty procedure and associated compliance matters; and Kerzner Palmilla Hotel Partners (and associated companies) on the tax aspects of its corporate restructuring. Key support comes from associate and former-PwC tax manager Esteban Gómez Aguado, who arrived in 2016, but notable associate Carlos Pérez-Chow left in mid-2017 to become tax director at Dentons López Velarde. In other work, the team provided counsel to Vamasa regarding an efficient tax structure for sale; Vector Partners on the design and structuring of a Mezzanine Fund; Tyco International on all the local tax aspect of its merger with Johnson Controls; and Corporación Inmobiliaria Vesta on all tax aspects of a financing from Metlife to fund debt repayment. Clients include Altum Fund, AIMCO, Brown Forman, Danone, Kerzner International, Lafarge, McGraw Hill, Sodexo and Telefonica.

With ‘a few good clients’ and ‘doing great work’ some are surprised that Ortiz, Hernández y Orendain, S.C.has not gainedthe profile that it perhaps should have’. Others note that ‘stand out figure’ Luis Ortiz, who retired from Basham, Ringe y Correa, S.C. back in 2014, ‘is not seeking to compete with everybody’. If it is therefore unlikely that the six-strong tax and international trade boutique will be growing aggressively in the immediate future, it nevertheless undertakes ‘very good, technically solid work’. Key tax-side partner Ortiz has ‘enormous prestige’ and is hailed as ‘one of the most talented practitioners in the market’ and ‘an outstanding tax attorney’, particularly for contentious cases: ‘Luis is a great litigator – he knows the courts, knows the judges and knows the law!’ His fellow founding partners Gerardo Hernández R and Ignacio Orendain manage the international trade and contentious aspects of the firm’s caseload.

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