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Baker McKenzie Abogados, S.C.

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

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Luis Carbajo

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Baker McKenzie LLP

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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.


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.


  • English
  • Spanish


  • 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


  • 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)



Within: Tax

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 Carlos Linares who has ‘enormous expertise’ (and can draw on the support of the firm's principal economist, TP-specialist Moisés Curiel), as well as Roberto Cardona who is ‘top tier in the tax litigation area’. The ‘active’ Jorge Narváez Hasfura, a member of the Global Value Added Tax steering committee, is also a key practitioner. 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.

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