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Baker McKenzie Abogados, S.C.

Baker McKenzie Abogados, S.C., Luis Carbajo, Mexico City,

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Luis Carbajo

Tel:
Work +525553514116
Email:
Baker McKenzie LLP

Work Department

Tax

Position

Luis Carbajo is a partner in Baker McKenzie's Tax Practice Group in Mexico City, where he advises multinationals on international tax planning, M&A, cross-border transactions and other business issues. He is a member of the Firm's Latin America Regional Tax Steering Committee, and an adviser to the tax committee of the National Maquiladora Council.

Mr. Carbajo frequently authors tax articles in Tax Notes International and the Practical Mexican Tax Strategies magazine. He also speaks at various seminars organized by CANIETI, CANACINTRA, Tax Executives Institute, Executive Enterprise Institute, Cámara de Comercio de Bogotá and the local Maquiladora Associations across Mexico.

Career

Mr. Carbajo focuses his practice on litigating and lobbying highly complex issues in the energy sector. He has extensive experience advising on permanent establishment issues, inter-company pricing, taxation of non-resident entities and individuals, and other corporate and tax matters such as VAT, assets tax, planning and litigation on social security contributions, and local and municipal taxes. His practice also covers tax planning and transfer pricing, particularly in the energy sector.

Languages

  • English
  • Spanish

Member

  • Texas-Mexico Bar Association - Member
  • Harvard Law School Alumni Association - Member
  • Mexican National Association of Corporate Counsels - Member
  • International Fiscal Association - Member
  • Mexican Institute of Finance Executives - Member

Education

  • Harvard Law School (Joint Degree International Tax Program/LLM) (1995)
  • La Universidad de Guanajuato (J.D.) (1995)
  • Harvard University (Certificate on Special Studies of Administration and Management) (1994)


Mexico

Tax

Within: Tax

Baker McKenzie Abogados, S.C.’s ‘excellent’ tax practice is particularly known for transfer pricing and tax disputes, both areas in which the team is ‘very strong’, say peers. For one client, the team is the ‘first choice, because the lawyers never put the company at risk. They offer a great service; they are very capable and knowledgeable of the industry. Their response times are good, and they are very professional’. The practice also stands out since, with 70 lawyers (including 15 partners) operating from five offices, it arguably offers unrivalled national coverage. Headline work saw practice head Luis Carbajo assist KBR with the design and implementation of a legal strategy to reach an out-of-court settlement regarding a tax inspection representing tax liabilities of approximately $209m. In another ongoing highlight case, Jorge Narváez and Roberto Cardona advised Adidas de México on a negotiation with the tax authorities regarding a transfer pricing adjustment following a disallowed deduction for income tax purposes of royalty and advertising expenses amounting to $20m. Narváez heads the firm’s Global Tax Dispute Resolution Group and handles tax litigation, transfer pricing and corporate reorganisation; Cardona has a ‘strong litigation background’ which he combines with tax planning. The two lawyers were supported by Carlos Linares who has ‘excellent transfer pricing skills and great experience’; he heads the firm’s regional transfer-pricing practice (and can draw on the expertise of the firm’s principal economist and TP specialist Moisés Curiel). Key figure Héctor Reyes (acting in conjunction with Cardona) assisted Walt Disney Studios Sony Pictures Releasing de México with the implementation of a legal strategy to recover a significant proportion of the single rate business tax ("IETU") paid during the fiscal years 2008 to 2013. Reyes also has extensive experience in international tax planning, M&A and cross-border transactions and inter-company pricing. Further support comes from Ulises Castilla, who assisted Carbajo with the KBR mandate; a former head of contentious matters at the SAT’s department for major contributors, he handles tax strategy and litigation. Victor Morales-Chavez was made partner in early 2018; his practice focuses on corporate taxes, non-resident taxation, international tax treaties and general tax planning; and José P Barnola Jr, a partner at the firm’s Caracas office, is currently working out of Mexico City and will do so for two years as part of the firm’s mobility programme. Other clients include Maersk, Cisco Systems, Reckitt Benckiser, and Bristol Myers Squibb.

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