Next Generation Partners

Tax in Bolivia

PPO Abogados

PPO Abogados offers a comprehensive range of tax services, including tax compliance, tax planning, international trade, customs, and tax structuring. The tax practice has a strong litigation team, representing multinational clients in both administrative and judicial litigation processes. The firm also provides tax accounting and audit services. Clients represent a range of sectors, and the team has recently advised on the tax aspects of significant M&A in a variety of areas. New points of focus within the practice include wealth management, digital economy taxation, and constitutional analysis of tax rules. The team has offices in Santa Cruz, La Paz, Cochabamba, Sucre, and Cobija, and the firm’s Canada Desk continues to enhance the group’s international reach. Tax specialist Pablo Ordóñez leads the practice and has a wealth of experience in international commodities, oil and gas, mining, litigation, and gambling regulation, and advises some of the firm’s key clients, including Minera San Cristobal and Inchcape. Appointed associate practice director in September 2023, Alexandra Ortíz leads the advisory and compliance segments, and has extensive experience in international tax planning, and advisory, compliance, and digital taxation. Senior associates Miguel Ángel Gumucio and Adrian Bellot are both experienced tax lawyers and come with client recommendation.

Practice head(s):

Pablo Ordoñez


Testimonials

‘I have worked with different firms in Latin America, and PPO has always been characterised by an exceptional service. The quality of the work is very good, and the attention of the team and follow-up are very valuable.’

‘The plus is the clarity with which they explain matters, which leads to a very detailed and technical analysis, the way in which they get involved and adapt to the project, the quality of the deliverables, and so on.’

‘The lawyers stand out for the quality of work they offer.’

‘PPO has an excellent team and the biggest strength I see is that the main partners are very well trained and up-to-date on an international level. They pass that knowledge on to their other partners. They are also excellently informed. They have an intelligence of information that I don’t see in other law firms. It is the only law firm that was aware of recent developments in my area, including green hydrogen.’

‘Its partners are highly qualified and have a high level of connection in Bolivia. This last point is outstanding given that, in Bolivia, it is very difficult to maintain a connection with everyone, public and private. It also has greater business vision than other law firms.’

‘It is a young team, with a lot of experience, knowledge and great response capacity. This is the team with which I have worked best. The treatment is personalised, taking suggestions into account, making improvements and exceeding expectations. It also shares knowledge on the internet: this office is much more technological than others.’

‘The lawyers explain clearly, they are closely related to companies in the sector and the treatment is personalised. The lawyers I can mention are Pablo Ordoñez and Alexandra Ortíz.’

‘I currently work with Adrian Bellot, and he is professional in the area and constantly monitors the requested jobs.’

Key clients

Rua Group


Alvarez & Marsal


DXN


Internet Bolivia


Telxius


WCS


Wellbore


Servisur


Inchape


Work highlights


  • Advised Inchape on the local aspects of its multi-jurisdictional, $1.5bn acquisition of Derco, analysing the corporate, regulatory, labour, and tax issues.
  • Acted for Belcorp in tax litigation related to corporate income tax.
     
  • Assisted Visa International with the design of tax policies for the promotion and acceptance of electronic payment.

Villegas Aldazosa & Asociados Soc. Civ.

The experienced tax team at Villegas Aldazosa & Asociados Soc. Civ. offers advice on local and international taxation, transfer pricing and M&A. The firm has continued to expand its client base, drawing new national and international clients such as Agropartners and Ingeser. Practice head Álvaro Villegas is an expert in tax law and has participated in the drafting of several laws and regulations. Within the tax department he focuses on restructurings and litigation. At the senior associate level, Christian Olea specialises in international taxation, litigation and transfer pricing. Milenka Salvatierra advises domestic and foreign companies on tax litigation and administrative processes, constitutional procedures and due diligence.

Practice head(s):

Álvaro Villegas


Testimonials

Our main motivation for choosing Villegas Aldazosa & Asociados Soc. Civ. is its value for money, specialisation in the tax and corporate field in Bolivia, and the decisive and transparent approach to each of the matters we have with it.

Sincerity and frankness in response. Specialisation and professionalism in each of its subjects. Special mention for Álvaro Villegas and Christian Olea.

Very good and highly responsive people. Good and fast understanding of foreign principles of law.

Key clients

Industrias de Aceite


Alicorp


Telefónica Celular de Bolivia


Granja Avícola Integral Sofía


Belia


Shell


Agropartners


Ghenva


Ingeser


Elementia


Accor Hotels


Thermomix


Tropical Tours Travel Agency


Archer DLS


TotalEnergies Bolivie


Indatta


Work highlights


  • Advised Alicorp on the design and implementation of tax initiatives for its subsidiary Industrias de Aceite.
  • Assisted Telefonica Celular de Bolivia with the design and filing of two challenges against tax assessments issued by the tax administration regarding VAT input costs of $4m.
  • Advised Shell Bolivia on the tax consequences of a debt payment to its parent company.

Araujo & Forgues

Tax specialist Araujo & Forgues provides tax advice and services to both national and international clients. The firm has extensive experience advising foreign companies on their incorporation into Bolivia, as well as Bolivian companies looking to establish operations elsewhere in Latin America. The firm assists clients with national and international tax planning, investments, project development and exports. Another area of expertise for the team is contentious matters: the group handles administrative appeals, contentious administrative judicial processes and litigation. Managing partner Jaime Araújo is based in Santa Cruz and is an expert in disputes against the tax authority. Jannine Forgues operates from the firm’s La Paz office, and has a strong background in the mining sector. Senior associate Joyce Clavijo Velarde is a tax attorney with experience in administrative processes in the Internal Revenue Services, and in litigation before the judiciary.

Work highlights


Benítez Rivas, Pérez & Asociados

Benítez Rivas, Pérez & Asociados is a tax boutique that gives specialised advice on a full range of matters, including tax planning and management. The group provides comprehensive advice on tax structure optimisation, disputes at both the administrative and judicial level, tax audits and foreign investments. The team advises a range of national and multinational clients from various industries, providing assistance throughout the life cycle of matters, from the preventative to the corrective, and disputes with the tax administration. Elbio Pérez is the director of the firm, while Adriana Sanjinés and Fabiola Gariazu are other key contacts in the team.

Work highlights


Dentons Guevara & Gutierrez

Dentons Guevara & Gutierrez provides a range of tax law services, from day-to-day advice, to tax efficient structuring and restructurings. The tax practice has a strong litigation team, representing clients in tax challenges and filing administrative, judicial and constitutional claims. The group has recently seen increased activity in the energy and natural resources sector and advised key clients from the mining and the oil and gas industries. With over 2o years of experience in the practice area, Mauricio Dalman leads the tax team and assists clients with national and international tax planning and corporate matters. He is supported by Rodrigo Rivera who is a seasoned litigator, with extensive experience in administrative and tax litigation. Senior associate Belén Montes advises clients on due diligence, administrative proceedings and dispute resolution related to tax matters, customs challenges and consultations. Nina Leguizamon is an associate to note.

Practice head(s):

Mauricio Dalman


Testimonials

The firm’s tax practice is of great excellence and the professional level of its leaders stands out in relation to other law firms.

Partners Mauricio Dalman and Rodrigo Rivera have high-level training and experience that position them very favorably in the market. This means they provide high-value services.

Multidisciplinary team with several years of experience in tax issues and the hydrocarbons sector.

Key clients

SantaCruz Silver Mining


The Church of Jesus Christ of Latter-Day Saints


PepsiCo


Ferroviaria Oriental


Universidad Privada Franz Tamayo


Trafigura


Cervecería Boliviana Nacional


Construtora Queiroz Galvao


Repsol E&P Bolivia


Petrobras Bolivia


Explora


Total Energies E&P Bolivie


SK Rental


Thales Group


Vintage Petroleum Boliviana


Tecpetrol de Bolivia


Work highlights


  • Represented Repsol E&P Bolivia in tax, constitutional and administrative matters.
  • Assisting Santacruz Silver Mining with a review of local tax matters of five target mining companies.
  • Acted for TotalEnergies E&P Bolivie before administrative and judicial courts, challenging administrative resolutions requesting payment of $14m and $27m, respectively.

Indacochea & Asociados

Indacochea & Asociados continues to grow its stand-alone tax department, advising clients on tax regulations, tax planning and customs matters. The team takes a preventative approach, performing tax audits and offering advice to clients on best tax practices. The firm also handles tax disputes, representing clients in litigation, conciliation and appeals before the internal revenue services. Candys Dorado leads the tax team, and has a wealth of expertise in tax regulations and disputes with the tax authorities, thanks to her experience working for the internal revenue services (GRACO). Associate Dolly Salazar has similar experience working in the public sector and heads the firm’s tax litigation practice.

Practice head(s):

Candys Dorado


Testimonials

The lawyers demonstrate high training and knowledge in commercial, tax and fiscal regulations, and capacities in the definition of the legal defense strategy, based on analysis of jurisprudence, case scenario and success expectations. I would highlight Candys Dorado and Dolly Salazar.

It is a well-prepared team, with a lot of knowledge on tax issues, that constantly sends us updates on tax issues so that we are informed.

Dolly Salazar and Candys Dorado handle the tax issues very well. I like the experience that Dolly has in tax matters, since she worked in taxes and knows all the processes very well.

Key clients

Interconexión Eléctrica


IMBA


Empresa Embutidos Monserrat


Alta Estetica


ARG


Imcruz


Work highlights


  • Assisting Imba with an administrative process against the tax authority for an alleged tax debt of approximately $2m.
  • Advising ARG on an administrative process and, at the same time, a judicial process before the Supreme Court.
  • Assisted Imcruz with an analysis of its income from the contributions and incentives of its brands, the possible contingencies for taxation in two or more jurisdictions and the counteraction of possible tax impacts and contingencies.

Moreno Baldivieso Estudio De Abogados

The tax team at Moreno Baldivieso Estudio De Abogados has an intricate knowledge of the Bolivian tax system, offering advice on tax regulations and complex administrative processes. The firm has experience handling a variety of tax-related matters, including international tax planning and structuring, tax audits, appeals and disputes. The firm has noted a recent increase in its tax-related advice to the construction sector, and related M&A transactions, while it continues to advise multinational businesses operating in Bolivia on a range of cross-border tax, legal and operational issues. The team is led by three lawyers: tax specialist Delfor Zapata, and Rodrigo Burgos and associate Moises Blanco, who both bring public sector experience to the group, having worked for the tax authority.

Practice head(s):

Delfor Zapata; Rodrigo Burgos; Moises Blanco


Key clients

Archer Daniel Midland (ADM)


Universidad Católica Boliviana “San Pablo” (UCB)


Aesa Ratings


Claure Group


Empresa Nacional de Telecomunicaciones (ENTEL)


Herragro


Capresso


Cooperativa Educacional Santa Cruz


Administración & Estructuras Phoenixtorres II


Empresa Minera Manquiri


Work highlights


  • Defended UCB in three legal actions initiated by the tax authority.
  • Assisted Aesa Ratings with a transfer pricing study after it faced a tax infringement action due to intercompany operations.
  • Advised Claure Group on the tax components of its project for the construction of a new football stadium and training facilities.

Bufete Aguirre, Quintanilla, Soria & Nishizawa Sociedad Civil – (BAQSN)

Advice on tax planning and the analysis and interpretation of treaties to avoid double taxation are among the noted strengths of the tax team at Bufete Aguirre, Quintanilla, Soria & Nishizawa Sociedad Civil – (BAQSN). The practice also handles administrative and judicial litigation. Mauricio Torrico Galindo heads the tax team from La Paz, assisting clients with tax planning and providing general advice and administrative resources before the tax authority. Gonzalo Prudencio Gozálvez leads the practice in Santa Cruz, focusing on legal strategic defence and litigating in processes challenging tax resolutions issued by the tax administration.

Practice head(s):

Mauricio Torrico Galindo; Gonzalo Prudencio Gozálvez


Key clients

AFP Futuro


Hidroelectrica Boliviana


Latam Airlines Group


Thales Las France


Huawey Bolivia


ONG Aldeas Infantiles SOS


Grupo H


JICA


Work highlights


  • Advised AFP Futuro on a preferential law third party procedure against the tax administration.
  • Assisted Granorte with tax processes related to exemptions of industrial properties.
  • Advised Latam Airlines on a tax treatment for general sales agents, and customs regulations applicable to an aeronautical warehouse.

Criales & Urcullo

Criales & Urcullo‘s tax team acts on international and domestic transactions, estate planning and private wealth. The firm has a strong client base, with clients from the banking and finance, real estate, oil and gas and utilities sectors. Luis Valda, an expert in tax law, is the main contact. Rubén Acuña, an auditor, adds experience to the group, while banking partner Javier Urcullo also supports the practice.

Work highlights


Ferrere

Ferrere handles a wide range of tax-related matters, including general tax consulting, international trade and customs advice, and the tax aspects of corporate and financial transactions. The team also has experience defining tax structures. The tax practice handles litigation, at both an administrative and judicial level, and represents clients in disputes with the tax regulator and the Bolivian state. The group continues to advise significant national and international clients, such as Cargill, and is led by senior associate Mauricio Viscarra, a tax specialist with extensive experience advising clients on tax planning, contingencies and litigation. He is supported by fellow senior associate Pablo Heredia.

Practice head(s):

Mauricio Viscarra


Testimonials

They have a great team, with solid knowledge in different areas, which makes the support it provides efficient.

Mauricio Viscarra is a highly qualified professional with solid knowledge, and his responses are timely.

Key clients

Cargill


Amazon


Ingener Sucursal Bolivia


Remote


EOCORP


HBO


Marriott International


Dufry


HIG Capital


Glencore


Tigre


Logicalis


Schlumberger


Jindal Steel


Brightstar


Moove


Work highlights


  • Representing a Schlumberger subsidiary in a tax proceeding for payment of municipal patents for $245,000.
  • Representing Cargill Bolivia in several tax proceedings related to tax credit for $145,000.
  • Advised Jindal Steel on a capital reduction and its tax consequences.

C.R. & F. Rojas – Abogados

The tax team at C.R. & F. Rojas – Abogados oversees day-to-day matters for a number of domestic clients, as well as multinationals with operations in Bolivia. The firm handles transfer pricing and tax litigation, but compliance remains the key strength of the group. Managing partners Pablo Rojas and Diego Aguilera are the key contacts for this practice area.

Work highlights


EY Bolivia

Local branch of the international consulting firm, EY Bolivia offers specialised tax advice in tax planning, compliance and due diligence, and the application of double tax treaties. The firm also assists with tax challenge processes, as well as analysing the tax consequences of commercial operations and expatriates’ activities in Bolivia. Senior associate Sandra Vásquez, who specialises in national taxation, tax consultancy, due diligence and assists clients with audits and litigation matters; co-leads the practice with public accountant Juan Pablo Vargas.

Practice head(s):

Juan Pablo Vargas Ramos; Sandra Vásquez Agramont


Testimonials

EY’s tax practice in Bolivia is characterised by its predisposition, dedication to service, proactivity and deep knowledge of Bolivian laws and regulations.

EY Bolivia’s tax practice stands out mainly for its predisposition in customer service. The presence, interest and continuous accompaniment on critical issues for us is remarkable.

The EY Tax team stands out for the composition of the team made up of people with extensive knowledge of: a) tax regulations and examination procedures; b) accounting knowledge and accounting treatment before a tax examination; c) experience in identifying the best way to raise the defenses for a better understanding of the inspectors. The EY Tax team stands out in the same way for the additional effort it makes to meet deadlines and the detailed review page by page of all the supports to be presented, taking care of each detail in order to avoid observations due to formal aspects.

The EY tax team stands out for all the additional effort it is willing to make in order to help the client with an adequate defense.

Juan Pablo Vargas – extensive knowledge and experience.

Sandra Vasquez stands out for her detailed review of each of the endorsements presented.

Key clients

Cervecería Boliviana Nacional


ZTE Bolivia


Bolívar Administración, Inversión y Servicios Asociados


Work highlights


  • Provided Cervecería Boliviana Nacional with permanent tax advice.
  • Provided Bolivar Administración, Inversión y Servicios Asociados with permanent advice.
  • Supported ZTE Bolivia in filing a lawsuit against a resolution issued by the Tax Administration regarding tax debt, and currently awaiting the issuance of the judgment.

Legal Accounting Services

Legal Accounting Services specialises in corporate tax and commercial law. The tax team advises national clients on compliance, and provides representation in any disputes that arise against the tax authority. The group is led by managing partner Janeth Sirley Torrez Perez, who has particular expertise in contentious matters.

Work highlights


Würth Bedoya Costa Du Rels Abogados

The tax team at Würth Bedoya Costa Du Rels Abogados represents companies and individuals on a national and international level, with experience in succession planning for family assets and maximising tax benefits, as well as corporate and business tax matters. The firm has a strong expertise in international tax planning, and handles compliance matters related to income tax, sales tax, and value-added tax. The group represents businesses in tax disputes and controversies with the Bolivian government. The team is led by Fernando Bedoya, who provides expert advice to clients on new Bolivian tax regulations, and associate Daniela Ayoroa Taborga, who has worked for the tax administration and has over 20 years of experience handling tax matters.

Practice head(s):

Fernando Bedoya; Daniela Ayoroa Taborga


Testimonials

A very committed work team, despite this being a new sector for the firm, that is very apt, and adapted to the processes in a very efficient way.

Key clients

Fundación Para La Producción (Funda Pro)


Nuevatel Pcs De Bolivia


Bizarro Bolivia


Multivac Group


LP Hoteles


Mavers – Clyde & Co Chile


Work highlights


  • Represented Nuevatel in an appeal before the tax appeal authority, challenging a determinative resolution issued by the national tax service denying the validity of a tax credit.
  • Advised Bizarro on comprehensive tax planning and compliance for public events in Bolivia.
  • Advised Mavers (Clyde & Co Chile) on tax planning and compliance for the drafting of a commercial agency contract in Bolivia.