Tax: The Big Four in Spain

Deloitte Legal

Praised by clients as ‘especially strong in the field of transfer pricing‘, Deloitte Legal's practice also fields expertise in advising on the tax structuring of M&A transactions, international tax, global investment and innovation tax incentives, indirect tax, global employment-related tax issues, and ESG-related matters. The client base includes major domestic and international financial institutions and corporations, high-net-worth individuals and family businesses. TMT, energy, pharmaceuticals and financial services are sectors of strength for the group. Newly appointed managing partner Nicolás de Gaviria heads up the team with transfer pricing expert Juan Ignacio de Molina, who leads the tax advice practice. Jose María Gómez Rosende, who heads the Spanish M&A tax practice, is a key contact. At principal associate level, Jorge Martín Girola Mariño focuses on M&A tax and Irene Reoyo Serrano acts for clients in the tourism, leisure and hospitality industries. The team was bolstered further in 2022 with the arrivals of former state tax inspector Carlos Serrano to lead the tax controversy prevention and resolution team, and Begoña Segovia.


Practice head(s):

Nicolás de Gaviria; Juan Ignacio de Molina


Other key lawyers:

José María Gómez Rosende; Marcos Rodríguez; Jon Arrarte; Miguel Gutiérrez; Jorge Martín Girola Mariño; Irene Reoyo Serrano; Carlos Serrano; Begoña Segovia


Testimonials

‘It is important to highlight how they take into account the client and their specific circumstances, always putting the client at the centre of their service. With regard to the billing process, this can be adapted to the specific needs of the client without reducing the quality of the service.’

‘The team’s main characteristic is to focus at all times on the client’s needs, maintaining continuous contact that facilitates the excellent provision of services. I would like to highlight Jorge Martin Girola.’

‘They seek to offer real solutions to customers. You do not feel like their interest is just based on your income; there is a real feeling that you are working together as a team.’

‘The team stand out for their relationships with clients and very personal service. They seek to generate lasting relationships that are built on trust over time.’

‘Excellent team management – they use technology but with an outstanding personalised perspective.’

‘The team is what makes this practice unique. We would like to highlight their knowledge, their availability and their involvement. They faithfully meet delivery deadlines and try to accommodate the company’s internal procedures as much as possible. They also work perfectly with our in-house team.’

‘Technical knowledge and availability.’

‘Especially strong in the field of transfer pricing, where they lead the market, and in the discussion of advance pricing agreements and mutual agreement procedures with the administration. I would also like to highlight the team’s work in the field of M&A.’

Key clients

Cinven


MásMovil Group


Silicius Real Estate Socimi, S.A.


Siemens Gamesa Renewable Energy, S.A.


Red Eléctrica Corporación, S.A. (Redeia)


Azora


Pharma Mar S.A.


Euskaltel and MásMóvil Group


Inmobiliaria Colonial SOCIMI, S.A.


A3 Media Corporación de Medios de Comunicación, SA


Iberdrola, S.A.


RSA LUXEMBOURG, S.A.


SINGULAR BANK S.A.


Naturgy


BBVA


Work highlights


  • Advised Euskaltel and MásMóvil Group on the tax aspects of the outsourcing of its FTTH fibre business.
  • Assisted Redeia with the tax due diligence process and structuring of the disposal of a 49% stake in Red Eléctrica Infraestructuras de Telecomunicación, S.A.U. (Reintel).
  • Advised BBVA on the tax aspects of the design and definition of a framework agreement for the common use of software IP among the group’s different affiliates.

EY Abogados

EY Abogados' tax department garners praise for its 'technical preparation, availability and flexibility'. The team stands out for its expertise in handling international tax and transactions, as well as advising major Spanish and international clients on tax due diligence and structuring high-profile, cross-border M&A mandates. Real estate tax, transfer pricing, local and environmental taxes, indirect tax and tax disputes are also key pillars of strength for the group. The practice is home to a strong private client team led by Javier Seijo Pérez, which focuses on assisting individuals and family businesses with wealth management and succession planning. Managing partner Ramón Palacín leads the group. Head of the private equity transaction practice Araceli Sáenz De Navarrete and Sonia Diaz, who focuses on M&A tax matters, are key figures in the team.

Practice head(s):

Ramon Palacín


Other key lawyers:

Araceli Saénz de Navarette; Javier Seijo Pérez; Sonia Díaz; Anil Bharwani; Antoni Murt; Juan Carpizo


Testimonials

‘The firm stands out for its teamwork in a multi-jurisdictional and multidisciplinary environment, in addition to the technical preparation of all the teams.’

‘What stands out is the technical preparation, availability, flexibility and close communication of the entire team, including Antoni Murt, who has directed and coordinated the matter in an exceptional manner and has been involved in all the work.’

‘In my opinion, the level of collaboration is transcendental, as is the team’s ability to understand the services we provide. The firm also provides up-to-date and prompt information on tax developments.’

‘Toni Murt stands out for private banking and wealth planning.’

‘What makes them unique is that they look beyond the purely tax and legal issues. This means not just informing us of the tax consequences of the transaction that we are proposing, but also analysing the alternatives and suggesting negotiation strategies, which goes beyond the usual advice and adds incalculable value for the client.’

‘Close communications, full availability and total alignment with our attitude towards tax matters: prudence, prudence and prudence.’

Key clients

Orange


Masmovil


EQT


Endesa


Rolls Royce


Antin


MATSA


KanAm Grund


Allianz Real Estate


Asprima


Santander


PAI Partners


AndBank


Work highlights


  • Assisted Orange with tax due diligence on MásMóvil before the proposed €19bn merger of the two companies.
  • Assisted Vauban Infrastructure Partners and Crédit Agricole Assurances with the tax aspects of the acquisition of a 45% stake worth €1.1bn in Telefónica’s rural fibre unit Bluevia.
  • Advised Canadian investment fund EQT on its €881m voluntary takeover bid for the entire share capital of renewable energy company Solarpack.

KPMG Abogados, Spain

KPMG Abogados, Spain‘s tax practice has a solid track record in advising on the due diligence and tax structuring of M&A transactions, and has extensive experience in domestic and cross-border matters. The team is also noted for its expertise in tax litigation, representing clients in disputes before national courts at all levels, as well as in the EU courts. Indirect tax, real estate tax, customs and excise duties, and financial services tax are also key drivers of work for the firm. Alberto Estrelles heads the team, which includes Julio César García Muñoz, who specialises in corporate tax and tax litigation; Víctor Mendoza, the leader of the financial services tax practice; and Carlos Marín, who heads the M&A and international corporate tax practice.

Practice head(s):

Alberto Estrelles


Other key lawyers:

Julio César García Muñoz; Víctor Mendoza; Carlos Marín; Natalia Pastor


Key clients

Santander Consumer Finance (Banco Santander Group)


CECA (Spanish Association of Former Saving Banks)


Inditex


Caixabank


Alberta Investment Management Corporation (AIMco)


KKR


CVC


China Three Gorges


Beam Suntory Spain


Amitra Capital


Work highlights


  • Assisted Alberta Investment Management with the tax issues arising from the transfer of its 97.3% stake in Eolia Renovables de Inversiones to Engie and Credit Agricole Assurances for €2bn.
  • Advised KKR on the tax aspects of its acquisition of a 49% stake in Red Eléctrica Infraestucturas de Telecomunicaciones (Reintel).

PwC Tax & Legal Services

The 'exceptional' team at PwC Tax & Legal Services has extensive experience in handling corporate and real estate tax work, advising on the tax due diligence and structuring of high-value transactions, often with international elements, and project developments. The firm also stands out for its strong tax controversy practice, which represents clients in disputes before national and EU courts. Other areas of expertise include transfer pricing and compliance matters concerning local and international tax regulations. Antonio Sánchez Recio, who focuses on advising major construction and real estate companies on corporate tax matters, and Javier González Carcedo, who is highly experienced in the field of international taxation and transfer pricing, co-head the team. Indirect tax practice head Alberto Monreal, Roberta Poza, who leads the international tax practice, and head of tax controversy Miguel Muñoz are also key practitioners.


Practice head(s):

Antonio Sanchez; Javier González Carcedo


Other key lawyers:

Alberto Monreal; Roberta Poza; Miguel Muñoz


Testimonials

‘Loyalty is a value to highlight. They present the advantages and disadvantages of the different possible approaches to an issue with great transparency and breadth of data, so that it is possible to look at the issues in a way that we found to be the most reasonable and advantageous.’

‘The team has great diversity of professional knowledge and personalities when approaching an issue or litigation, which allows them to have a broad vision of the different options and strategies for success in the process.’

‘Javier Gonzalez Carcedo has extensive experience in negotiating agreements with the administration and great brilliance and flexibility when coming up with proposals and options.’

Key clients

Brookfield Asset Management


Distrito Castellana Norte, S.A.


Vitrolife AB


Siemens AG


Tecnicas Reunidas


Abasic (Desigual)


BBVA


Work highlights


  • Advised Brookfield Asset Management on the tax aspects of its acquisition of an 85% stake in Cupa Group.
  • Assisted Spanish real estate development company Distrito Castellana Norte, S.A. with the calculation of state, regional and municipal taxes relating to the development of the Madrid Nuevo Norte project for an economic sustainability report.
  • Advised Vitrolife AB on the tax aspects of the share purchase agreement for its combination with Igenomix.