Tax in Bolivia

PPO Abogados

PPO Abogados 'extremely proactive ’, six-strong team advises on a wide range of tax matters, from general tax consulting, international trade and the tax aspects of corporate and financial transactions, to the definition of tax structures and both administrative and judicial tax litigation. Tax policy design is another niche strength. Practice head Pablo Ordoñez has a full spectrum tax practice, including litigation, and has particular experience regarding international commodities and oil and gas. Senior associates Alexandra Ortíz (tax planning and advisory), and Ysabel Rodas (tax advisory from both a technical accounting and legal perspective), are additional practice contacts. Associates Miguel Ángel Gumucio (tax planning, international trade) and María Laura Coimbra (tax and foreign investment, tax and customs litigation), are also noted.

Practice head(s):

Pablo Ordoñez

Testimonials

The team has shown excellent results in its management of tax matters on behalf of the company. It is a highly qualified and highly proactive team.’

Pablo Ordoñez, Ysabel Rodas and Miguel Ángel Gamucio stand out for their client care, dedication and proactivity’.

Key clients

BBO Bebidas Bolivianas

Copasa (Bolivia)

Dufry

Ericsson

Helmerich & Payne

Makiber (Bolivia)

Nestlé

Pharmatech

RUA Group

Schlumberger

Work highlights

  • Permanent advice of construction company Makiber (Boliva) as regards matters before the tax authority, the tax implications of strategic decisions, double taxation and VAT matters, among others.
  • Assisted Nestlé with the analysis of its operations in relation to VAT, CIT, customs and other local taxes on property and economic licenses owed to municipalities in the country.
  • Permanent advice to Belorp regarding tax and customs matters, including fiscal opinions on new business models, lines and contractual structures; and representation in contentious tax and customs matters.

Villegas Aldazosa SOC. CIV

Santa Cruz-based corporate and tax boutique Villegas Aldazosa Soc. Civ opended its doors in late 2019, founded by Álvaro Villegas following the dissolution of longstanding market-leader Tufiño y Villegas (a move which also saw his former partner, senior tax figure José Luis Tufiño, establish Tufiño & Asociados in La Paz). The founder and a former president of Bolivia's branch of the IFA, Villegas heads up a five-strong tax group which focuses primarily on local and international taxation, and transfer pricing; particularly well-versed in transactional tax, restructuring and tax litigation, oil and gas sector matters are a core specialty. Other clients are drawn from the construction, agribusiness and telecoms sectors. Very much an up-and-coming figure,  highly experienced senior associate Sandra Vasquez focuses on due diligence, litigation, local taxation and tax procedure; associate Christian Olea, currently completing his LLM in international taxation, is also noted.

Practice head(s):

Álvaro Villegas

Key clients

Petrobras Bolivia

Alicorp

Shell Bolivia

Elementia

Industrias de Aceite

Millicon International (TIGO)

Longfu Bolivia

Granja Avícola Integral Sofia

Profarm

Corporación Mathiesen

Salaberren y López Sansón (SYLS)

Gehnova

Work highlights

  • Represented Industrias de Aceite in over 40 challenges to tax assessments issued by Bolivia’s tax authority, Servicio de Impuestos Nacionales (SIN), concerning exports.
  • Acting for technology company Longfu Bolivia in a dispute regarding customs valuation of imported goods.
  • Advised Petrobras Bolivia on acceptance of the Tax Amnesty Law (No. 1103) achieving the curtailment of all the penalties established in six tax law suits.

Araujo & Forgues

Tax and corporate boutique Araujo & Forgues has a growing practice offering but perhaps remains best known for its broad tax offering, which handles mattes such as sector specific tax advisory in areas including oil and gas, energy, and mining; customs and international trade matters (including FTAs and maquiladoras); tax planning, structures and compliance, as well as transactional tax matters. Acting from Santa Cruz and La Paz, respectively, Jaime Araújo is particularly known for litigation against Bolivia's tax service and Jannine Forgues also handles both contentious and non-contentious tax matters; the pair co-lead the practice.

Practice head(s):

Jaime Araújo; Jannine Forguez

Benítez Rivas, Pérez & Asociados

Operating principally from La Paz, the five-strong team at tax boutique Benítez Rivas, Pérez & Asociados advises a prestigious client roster from a broad swathe of business sectors on the full range of tax advisory and disputes - including tax audits, optimisation and preventative training, among other matters - on an ongoing or one-off basis. Managing partner and practice head Elbio Pérez's extensive expertise is informed by commercial, insurance, finance and capital markets knowledge. Tax-specialised accountant Adriana Sanjinés and Fabiola Gariazu (who covers the gamut of tax matters, from tax advisory and planning to tax litigation in both judicial and administrative instances), are also key names.

Practice head(s):

Elbio Pérez

Key clients

Telecel (Tigo)

Huawei Technologies (Bolivia)

Petrobras Bolivia Inversiones Y Servicios

Repsol Sucursal Bolivia

Compañía Industrial de Tabacos (CITSA)

Sociedad Boliviana de Cemento (SOBOCE)

Cervecería Boliviana Nacional CBN

ADM

Banco de Crédito de Bolivia BCP

Bolsa Boliviana de Valores

Alianza Seguros Generales

Banco Interamericano de desarrollo BID

Corporación Andina de Fomento CAF

Indacochea & Asociados

Senior partner Mariana Pereira and senior associate Candys Dorado jointly head Indacochea & Asociados ’ six-strong tax practice, which advises local and international clients on advisory and contentious mandates; defending clients against tax rulings is a key capability of the department. Tax and administrative specialist Dorado, can draw on over ten years' experience at Bolivia's inland revenue service; with a specialisation in international economics, she also advises on international trade and customs matters. The team is also noted for handling the tax aspects of corporate matters. The group was bolstered by the July 2019 arrival of associate María Alexandra Salvatierra, formerly at Bolivia's Tax Bureau, who handles tax planning, tax legal audits and inspection processes, as well as counsel on administrative and judicial procedures and litigation, the strategic planning of operations and national regulations and tariff issues.

Practice head(s):

Mariana Pereira; Candys Dorado

Key clients

Industrias Alimenticias Fagal

Total Media Networks

Farmacias Chavez

Louis Dreyfus Commodities

ISA Bolivia

Bayer Bolivia

Imcruz

Work highlights

  • Counsel to an oilfields service company in an adminsitrative process initiated by the tax bureau.
  • Counsel to a design and marketing group regarding the design of a new tax strategy.
  • Advising a client on the analysis of all its legal and accounting documentation in relation to tax credits.

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

Bufete Aguirre, Quintanilla, Soria & Nishizawa Sociedad Civil – (BAQSN) is the product of the merger of two major corporate law firms in late 2018. It's 'efficient ’, five-strong tax team advises a broad client roster on matters including tax planning, litigation (both administrative and judicial), tax treatment matters, and the analysis and interpretation of tax treaties. Mauricio Torrico, whose practice covers corporate and labour law as well as tax; and Milenka Saavedra, whose broad offering includes tax and customs matters - particularly tax compliance - share leadership of the practice with Santa Cruz-based tax specialist Gonzalo Prudencio, whose former experience includes time at national tax service SIN and the Superintendencia Tributaria; his practice covers tax advisory, planning and litigation.

Testimonials

An efficient team’.

The team always sends information with the adequate legal back up reference. They take the time to document all so that you can refer back to it. This was not the case with our prior attorneys.’

They are serious with the work and information they yet bring a human and personal empathy to the discussions.’

They have a multi-disciplinary team in different areas, so the answers to our queries and advice on different topics are immediate, very appropriate and with an impeccable ethic. The plus of this law firm: in addition to what has already been mentioned, they can do so in Spanish, English or Japanese.’

They have a good distribution of resources, with lawyers specialised in different areas that have allowed us in many cases to have a broader vision and advice.’

They have an immediate response to the different situations raised. They are always predisposed to collaborate, and advise us on the paths to follow, proposing various options when faced with the same problem. We recommend Gonzalo Prudencio and Julio Quintanilla.’

Key clients

LATAM Airlines (Bolivia)

Hidroelectrica Boliviana

Marie Stopes (Bolivia)

Atlas Copco

Hidroelectrica Boliviana

Global Supertanker Services

Clifford Chance

Aldeas Infantiles SOS Bolivia

Grupo H

Institute de Recherche Pour le Developpement (IRD)

Atlas Corp Group

JICA

Work highlights

  • Advised American Express on the tax treatment applied to certain payment structures provided by the client and related to royalties and services.  
  • Advised an automotive manufacturer on the tax aspects of the closure of its Bolivian branch.

Criales & Urcullo

Best known as a banking and finance boutique Criales & Urcullo ’s tax practice is becoming an increasingly core practice, particularly for international tax work. Led by tax spcialist Luis Valda ( The 'very committed ’ team, composed of both accountants and lawyers, assists a broad array of clients on matters including national and international tax planning, audits, customs and international trade, and contentious tax issues, both judicial and administrative. Also at partner level: José Criales (who is noted for his 'strategic approach to all legal matters ’) and auditor  Rubén Acuña are additional key contacts; also noted are associates Laura Rivas (who is dual-qualified in Boliva and Chile), and Diego Mojica , also on the auditing side. Financial adviser Gabriel Galarza left the firm in January 2020 .

Practice head(s):

Luis Valda

Testimonials

A very committed team, well oriented to provide solutions in a timely manner. As compared to other firms, Criales & Urcullo engaged top lawyers to handle my legal matters. Creative solutions to long-standing questions in our industry.’

Jose Criales is a very experienced lawyer with a strategical approach to all legal matters. Luis Valda has an impresive knowledge of complex tax matters. We received advice from him that effectively solved our problems.’

The C&U Tax practice has been effective and successful in its interventions, they fully apply the experience acquired with other clients.’

Luis Valda… has a thorough knowledge of tax regulations and the tax philosophy on which the bases of Bolivian Tax Policy have been established. Additionally, she adds a personal touch to our way of working; she’s a friendly counselor in all cases.’

Key clients

CABOLQUI

Grupo Adler

The Pan American Group

Empresa Minera Industrial y Comercial Lambol

The Church of Jesus Christ of Latter-Day Saints

Grupo Empresarial Lafuente

Banco para el Fomento a Iniciativas Económicas (Banco FIE)

Compañía de Inversiones

Grupo Panamerican

Ingeniería, Estudios y Proyectos

Bolsa Boliviana de Valores

Grupo SAIV

Empresa Minera Lambol

Cámara Boliviana de Exportadores de Quinua (CABOLQUI)

Bolívar Administración e Inversiones (BAISA)

La Papelera

Grupo Magri

Work highlights

  • Assisting Fundación SOLYDES with the tax planning for Bolivia’s first start-up accelerator fund , which will provide seed funding from international investors to Bolivian entrepreneurs.
  • Assisting software company Actualisap Consultores Bolivia with the tax planning for the incorporation of an international holding company, to finance the expansion of its operations in Latin America via new investment.
  • Advised three Bolivian tour operators on compliance with the country’s tax amnesty program.

Guevara & Gutiérrez S.C

Focused on complex matters, particularly related to major projects and structuring, the tax practice at Guevara & Gutiérrez S.C supported by the firm's broader service offering - particularly the administrative and corporate teams - seeks to offer a one-stop-shop service. The Bolivian member of the Latin American Tax & Legal Network (LATAXNET), it's mandates range from early-day advice on projects prior to their structuring, tax optimisation and general tax matters, to tax litigation - a key strength - in both administrative and judicial instances. The practice is also prominent on the tax aspects of major corporate and energy-sector instructions. Practice head Mauricio Dalman focuses on international planning, corporate and tax advice and the development of optimum tax structures for businesses operating in Bolivia. Dalman is also deeply experienced tax litigator before the administrative, judicial and constitutional courts, and can also call on contentious partner Rodrigo Rivera, who also has tax disputes experience. However, the team has endured departures, with former key senior associate Julio Landivar’s move in-house as head of legal at YPFC Chaco in February 2020, following on the heels of the June 2019 exits of associates Belén Montes (to EY) and Mauricio Viscarra (who subsequently joined PPO Abogados). Since publication the firm has announced a tie-up with Dentons, effective as of mid-March 2021.

Practice head(s):

Mauricio Dalman

Key clients

Explora

Petrobras (Bolivia)

Trafigura

Repsol E&P (Bolivia)

The Church of Jesus Christ of Latter-Day Saints

PepsiCo

Universidad Privada Franz Tamayo

Cervecería Boliviana Nacional

Construtora Queiroz Galvao

Work highlights

  • Representing Repsol E&P Bolivia in a constitutional recourse against a tax authority resolution; value $17m.
  • Assisting Explora with tax planning and structures for the expansion of its business in Bolivia, including advice on differing tax scenarios in order to achieve optimal tax efficiency

Moreno Baldivieso Estudio De Abogados

Noted for its particular experience in assisting the firm's corporate department with the tax-related aspects of sizeable mandates, Moreno Baldivieso Estudio De Abogados’ department is very well versed in handling tax litigation. Other recent mandates have seen the firm undertake tax audit processes, structuring, represent clients in judicial and administrative claims and collection actions; and the analysis of the tax impact of various types of corporate acquisitions, divestitures and restructuring processes. Particularly active in the mining, agrobusiness, financial services and telecoms sectors, recently, the practice is co-led by Delfor Zapata, Luis Moreno and key figure, counsel Rodrigo Burgos: a former national manager at Bolivia's tax service who also spent some 15 years at KPMG. An accountant as well as a lawyer, Burgos has Master’s degrees in both tax law and public policy. Additional support comes from corporate senior associates Teddy Mercado and Daniel Virreira.

Key clients

Archer Daniel Midland (ADM)

Votorantim Cementos

ACI Systems Alemania

Industrias Venado

Banco do Brasil (Bolivia)

Fidelidade Companhia de Seguros

Pan American Silver

MSC – Mediterranean Shipping Company (Bolivia)

Bunge

CAF

Work highlights

  • Assisting Industrias Venado with the tax aspects of its proposed M&A transaction for the purpose of selling the company.
  • Successfully defended mining company Compañia Minera Tiwanacu in litigation concerning the payment of capital gains tax after selling a 78% stake, worth $19m, in an affiliated company to a Canadian entity.
  • Provides ongoing tax advice to regional development bank CAF.

C.R. & F. Rojas – Abogados

The four-strong team at C.R. & F. Rojas – Abogados including in-house CPA Américo Melgar, focuses primarily on tax compliance, but also advises on the tax aspects of transactions, customs law and a limited volume of tax litigation. Diego Rojas and Pablo Rojas lead the practice from Santa Cruz and La Paz, respectively. Much of the team's caseload is dedicated to day-to-day and strategic compliance advisory, along with advice on the tax aspects of inbound investments and transactions.

Practice head(s):

Diego Rojas, Pablo Rojas

Key clients

Triada (Bolivia)

FMC Laitnoamerica (Bolivia)

Bioquim de Boliva

AGRYBEN

Jeunesse Global (Bolivia)

APC Bolivia

Tamoin Bolivia

GMI Bolivia

Vergara & Asociados

Tax and international trade boutique Vergara & Asociados is the first legal firm in Bolivia to gain ISO 9001 (2015) quality certification for its tax litigation (where it has its own patent software) and business process outsourcing. The ten-strong team is led by manging partner Rafael Vergara Sandóval and tax director Julio Vera de la Barra in La Paz, Issel Suárez Menacho in Santa Cruz and Ana María Mendoza in Sucre. It’s offering includes preventive advice on tax compliance and defence in litigation regarding local tax interpretation and international taxation; as well as tax and customs procedures, transfer pricing, judicial processes and constitutional actions to protect taxpayer's rights.

Practice head(s):

Rafael Vergara

Testimonials

Our experience has been very good collaborating with their team on important tax matters in Bolivia, which they were involved in as international advisers.’

We worked with Dr. Rafael Vergara with whom we had a very good experience due to his dedication to his work.’

Key clients

Starbucks / KFC (DELOSUR)

ADRA Bolivia / Project Concern International (USAID Agencies)

Tiwanacu Mining Company

Epson (Bolivia)

Bolivian Petroleum Equipment

FEXPOCRUZ

Brenntag (Bolivia)

Audio Visual Multimedia Systems

Acuraflow

DACAS

CEIEC International

Cardore & Cadore

CIDEPA

National Chamber of Customs Dispatchers

AgroBolivia Agricultural Company

Sony Chile

Tecnomyl

Pro Mujer (Bolivia)

World Gospel Mission

Work highlights

  • Represented USAID agency ADRA Bolivia in litigation against the tax administration, on appeal and in the Supreme Court, obtaining a favourable interpretation of international agreements; value $20m.