Tax in Chile
Baraona Fischer & Cía fields a 20-strong tax practice (of which 55% are women) that is led by Alex Fischer (a former co-head of Carey’s tax group), and includes senior partner Juan Manuel Baraona, who is widely recognised as a leader in tax matters. The team is further supported by partners Carolina Collantes, Isabel Espinoza and Juan Cristóbal Ortega, who advise on a broad spectrum of tax-advisory areas, including general corporate matters, M&A, financing, transfer pricing, and estate planning and structuring. In addition, the firm boasts a tax-litigation team that benefits from senior legal counsel, Francisca Villamán (former legal head at the tax authority’s Large Taxpayers Unit); provides tax-compliance services, headed by Boris León; and houses a group of twelve auditors. Key senior associate support is provided by Juan Cristóbal Valenzuela. Since publication, the firm has announced its division (as of 1st January 2021) into two entities, with Baraona accompanied by Vilamán at Baraona Marshall & Cía, while the remainder -and bulk- of the tax team is now at Fischer & Cía.
‘An outstanding tax law practice with great knowledge of the market.‘
‘They know the tax system in its entirety, from the administrative sector to the judiciary, and they know the different tax systems prevailing in Chile, including the special regimes. This team stands out from other law firms.‘
‘Alex Fischer is a recognised expert in this area, with great technical ability and an extraordinary ability to explain the particularities of local regulations to foreign clients, including in criminal tax matters.‘
‘Carolina Collantes is an excellent professional with strong analytical skills and deep knowledge of her field.‘
Banco de Chile
Banco de Crédito e Inversiones
City National Bank, Florida
- Acted for Banco de Chile in a tax claim before the Tax Court, which related to a number of tax assessments.
- Advised Banco de Crédito e Inversiones and City National Bank, Florida on the tax aspects of an aeroplane financing.
Barros & Errázuriz's sizeable 17-member tax department is widely respected for its national and international tax planning strategies, as well as its tax law advice on M&A, joint ventures, corporate restructuring and project finance. In addition, the practice has extensive experience in proceedings before Chile's IRS and tax courts; and is frequently instructed by US clients in relation to Foreign Account Tax Compliance Act (FATCA) compliance processes. Founding partner Fernando Barros heads the tax practice, which also fields María Teresa Cremaschi (who has over 20 years' experience in tax matters at national and international level), and Carola Trucco (who handles the tax aspects of cross-border operations, M&A and business reorganisations). A strong second line of senior associates includes transactional tax-structuring specialist, Evelyn Sepúlveda, and tax dispute resolution expert Mauricio Bascuñán. Since publication, however, an eight strong team including Cremaschi and Sepúlveda has left for MB Abogados, effective as of March 2021.
‘The tax team is responsive and practical, and helps us to navigate the changes in Chilean tax efficiently and practically. The firm’s tax team is the best I have come across.’
‘I have been pleasantly surprised by the experience that its staff have previously had in public government entities, which allows a different vision when making decisions.‘
‘This law firm is definitely above other prestigious firms. The team is highly competent and extremely motivated, and its people are of the highest quality, both at personal and professional levels.’
‘They are able to resolve complex tax matters and are a strong competitor to peers. We have had excellent results with Carola Trucco.‘
‘Carola Trucco and Evelyn Sepúlveda are excellent at providing practical advice and navigating through confusing situations.‘
Sura Asset Management
La Casa de Piedra
MCC Corredores de Bolsa
- Advised Harvard Management Company on the tax issues concerning the group’s investment and financing structure in Chile.
- Advised La Casa de Piedra on the VAT issues related to the sale of an industrial property.
- Assisted Agrosuper with the tax aspects of a purchase and sale agreement.
- Advised Total Eren on the tax issues surrounding the purchase of 50% of a solar project.
- Ongoing advisory to Esmax regarding its tax matters, previously involving a corporate reorganisation process.
Carey's large, 24-strong team is highly rated for its tax law expertise in relation to the finance, insurance, energy, infrastructure and technology sectors, among others. It includes certified accountants and an economist who support the practice's expertise in tax consulting, planning, due diligence and audits, along with administrative procedures before Chile's IRS and tax litigation. Manging partner Jaime Carey and Jessica Power ('committed to clients') both focus on personal and corporate tax planning, local and international tax consulting, and the tax aspects of M&A and foreign investment transactions, among other matters. They co-head the practice with December 2019 partner-promotion, Manuel Garcés, whose practice includes local and international tax consultancy, corporate tax, VAT and tax litigation. Notable support at associate level is provided by Ximena Silberman and Daniela Pfeffer. Since publication, the firm has welcomed back Manuel Alcalde -as a partner- after serving as the Chilean Ministry of Finance's Head of Tax Policy for the past three years (effective as of mid-April 2021).
‘The team’s degree of specialisation in an area as complex as tax law makes the advice in this area exceptional.‘
‘The team has good knowledge of the domestic and international tax aspects of the transactions and is able to provide timely and accurate input whenever required.‘
‘The speed in delivering well-founded and robust responses makes us fully trust the advice.‘
‘It is a very professional team, but also human.‘
‘Jessica Power is committed to clients.‘
‘Jessica Power is talented, always approachable and quick to answer. She manages to understand the problems or issues that are entrusted to her very quickly.‘
‘Jaime Carey worked closely with his team to obtain the best possible result for his client in a very efficient way, even when the transactions were highly complex and required the involvement of advisors in multiple jurisdictions.‘
‘Jaime Cary is a real asset in the search for solutions.‘
MetLife Compañía de Seguros
At multinational professional services firm EY Chile, the sizeable practice includes eight lawyers, 10 certified public accountants and two economists, and demonstrates notable expertise in tax planning, compliance, and tax litigation. The 'very competent team' also advises on the tax aspects of transactions and complex wealth-management issues. Corporate and international tax expert Javiera Contreras heads the tax practice, which also fields experienced partner Pablo Greiber, who is known for his tax work involving companies, individuals and family businesses. Also recommended at partner level are Alicia Domínguez, Darío Romero and Cristián Sepúlveda Reed. In 2018, Macarena Navarrete assumed the position of country managing partner, reportedly becoming the first woman among Chile's 'Big Four' firms to achieve such status.
‘EY has advised us on tax matters involving M&A as well as corporate aspects. It is a very competent team, with very solid legal and ethical standards, and which gives great peace of mind that things are well done and with a high level of legal certainty.‘
‘Great customer orientation and analysis capacity – an experienced team.‘
‘We like its preparation, experience and great customer orientation. It is a great support for the company.‘
‘Great for commitment and level of response, with high technical knowledge and they are very up to date with reforms, circulars and legal news.‘
‘The members of each area are first class. And they have the international EY platform that clearly gives a seal of guarantee and an information platform that makes it very avant-garde in what they do.‘
‘Cristián Sepúlveda Reed is an excellent lawyer who also handles commercial aspects very well.‘
The team at KPMG in Chile is over 35-strong and handles domestic and international tax consultancy and tax disputes, along with the tax issues related to acquisition structuring, corporate and labour law, transfer pricing, capital markets, and reorganisations. The group also has a significant compliance practice. The firm's lead partner Francisco Lyon is the current President of the Chilean branch of the International Fiscal Association; Rodrigo Stein, Mauricio López and Andrés Martínez all have over 15 year's tax practice experience; and Alberto Cuevas is a former tax policy coordinator of the Ministry of Finance. Additional partner strength is provided by Luis Seguel and Pedro Castro, with director Gloria Flores, senior tax manager Juan Infante, and manager José Miguel Gazitua (who re-joined in 2019 from Fuensalida & Del Valle Abogados) providing further support. Since publication, López and Flores have both moved to Recabarren & Asociados.
Claro & Cia.'s 11-strong group, plus a further three tax accountants, advise on a broad range of tax advisory and transactional matters, along with an increasing number of tax cases before the recently created tax courts. The practice is particularly active in relation to the banking, retail, aeronautics and maritime sectors. Clients also benefit from the firm's full-service expertise in M&A, capital markets and project finance. Regularly advising both corporate and family office clients, Jorge Carraha is the experienced tax department head; while at senior associate level, the tax focused Nicolás Maturana has been active in transactional and litigation matters of late - and also has knowledge of wealth management.
‘The team’s strengths and key capabilities are its broad experience and provision of service with high ethical standards. It is also committed to its clients.‘
‘A highly specialised and reliable team that avoids generating expectations and bases opinions on reality. It compares very favourably with other firms.‘
‘Excellence service and their well-known leadership is always present during the firm’s high-level legal performance.‘
‘A great team – the commitment and availability to solve the client’s problems can be seen. They have technical knowledge and experience of complex subjects.‘
‘Jorge Carraha is an highly experienced professional in the Chilean market. His vast experience gives clients confidence in his good professional judgement. He also knows what clients expect from his legal advice and we feel that he is committed to the company’s interests.‘
‘Jorge Carraha has formed a team of very committed and hardworking young professionals. Jorge’s dedication and expertise in the matter is evident, which he has managed to transmit to his team.‘
‘Jorge Carraha has great availability and is very much in tune with the changes that have taken place in the world and in Chile regarding how to face tax problems – good team management too.‘
‘Senior associate Nicolás Maturana has a great future and is attentive to clients’ needs and provides clear solutions.‘
Asesorías e Inversiones Benjamín
Sudamericana Agencia Aéreas y Marítimas
The Bank of Tokyo-Mitsubishi
Occidental Chemical Chile
Compañía Sud Americana de Vapores
- Advised Parque Arauco on the tax aspects of the acquisition of Mall del Centro de Concepción.
- Advised The Bank of Tokyo-Mitsubishi on the tax issues arising from parent entity MUFG Bank’s restructuring of its overseas business and branch network.
- Provided tax advice to Nutrien on the sale of 62m-plus series A shares in SQM.
Fuensalida & Del Valle Abogados
A strong promoter of gender parity and equal opportunities, tax boutique Fuensalida & Del Valle Abogados is experienced in tax litigation, securities and capital markets taxation, as well as tailor-made domestic and international restructurings. Jaime Del Valle advises on the tax side to restructuring and M&A, as well as on day-to-day tax matters and tax planning. The department expanded through the return of tax expert Carolina Fuensalida (after completing work on the Government's tax reform bill); and the hiring in March 2020 of senior associate Pablo Quezada from the Chilean IRS' General Directorate for Large Taxpayers, where he was head of administrative procedures. Providing further support are Cristóbal Ureta, senior associate Trinidad Fernandez and associate Pelayo Valdivia.
‘The legal team of Fuensalida & DelValle is frankly first-rate; they always play a leading role during all discussions at country level; and despite being an office with tax experts, they always manage to provide a global view of issues. The level of professionalism and dedication of the service they deliver is seen in the level of detail and depth with which they take each subject. For me, if the work is done by Fuenzalida & Del Valle, it is synonymous to being well done.‘
‘Their knowledge and efficient way of solving queries are great, and they have good relationships with the authorities, where they are received seriously and professionally.‘
‘Great for quality of care and knowledge. This is a well-coordinated, highly informed, efficient and assertive team that is very serious in its responses and advice. In my opinion they compare favourably with teams from other firms. The professionalism and high level of knowledge and tax strategy characterise them.‘
‘They are constantly up-to-date on topics, provide very personalised attention and are widely available. They exceed the average when compared to other firms in terms of expertise and updating, and they are at the forefront of where the world is moving in these matters.‘
‘They are differentiated by their high specialisation in the area of tax consulting. I think that the partners have their responsibilities well distributed and form a reliable work team for clients.‘
‘Carola Fuensalida amply demonstrates her experience and extensive knowledge, in addition to her good relations with the tax authorities. She plays a fundamental role in public policy.‘
‘Jaime del Valle is great for detail and Cristóbal Ureta shows empathy.‘
‘Jaime del Valle displays great professional training and Cristóbal Ureta demonstrates his dedication to client problems, with great knowledge in the corporate and tax area.‘
Principal Financial Group
Asociación de Fondos Mutuos
Autorentas del Pacífico
Colmena Golden Cross
Compañía Minera Doña Inés de Collahuasi
Santander Asset Management
Costa Verde Aeronáutica
Consultora e Inmobiliaria Roca
- Advised MBI Inversiones on the tax structure for the sale of a real estate complex, comprising a shopping mall, office tower and hotel tower.
- Advised Unifrutti International Holding Group on the tax aspects of a $250m international bond issuance.
- Advised BCI on the tax aspects of its acquisition of the credit and financing business of Walmart Chile.
The 12-member group at Philippi Prietocarrizosa Ferrero DU & Uría is well known for its tax assistance regarding complex corporate, M&A and private wealth matters, along with tax planning and structuring, across a broad swathe of industry sectors including agriculture, banking and finance, healthcare, insurance, media, natural resources, telecoms and transport. It is also active in tax litigation and administrative procedures before the tax authorities. Mario Silva, who predominantly acts for corporations, family offices and private wealth clients; and Guillermo Infante, who handles tax-related finance, energy and natural resources, and M&A work; co-head the department. Additional key contacts include principal associate Arturo Selman, who is tax disputes head; and senior associate Magdalena Munita Irarrázaval who is a tax planning expert.
‘Rated for its knowledge and quality of solutions and ideas.‘
LATAM Airlines Group
DiDi Mobility Information Technology
21st Century Fox
Empresa de Transporte de Pasajeros Metro
- Advised Metso Oyj on the tax aspects of its purchase of HighService Corp, which provides mechanical, electrical and maintenance services for mining companies.
- Advised DiDi Mobility Information Technology on the identification of key tax matters in relation to the development of its business in Chile.
- Assisted LATAM Airlines with the preparation of a legal opinion concerning the applicable tax treatment for the repurchase price of securities.
PricewaterhouseCoopers Consultores, Auditores y Compañía Limitada
PricewaterhouseCoopers Consultores, Auditores y Compañía Limitada is the Chilean branch of global, multidisciplinary firm, PwC. It is, arguably, best known for international taxation, but is equally active handling the tax aspects of financing deals, M&A transactions and complex restructuring processes. Other areas of particular focus include transfer pricing, compliance, and tax disputes and litigation. Key figures include Sandra Benedetto, an international taxation expert; Loreto Pelegrí who focuses on tax structuring matters (and was elected as member of the Global Board of PwC International in 2019); and Francisco Selamé, head of the tax and legal for the firm's Latin America Network.
The 10-member team at Prieto Abogados 'has extensive knowledge of tax issues in Chile and the region'. It is highly experienced in the tax structuring of investments in -and financing of- energy, ports and public utility developments, among other projects. The department also house a private client sub-practice, handles tax planning for family offices and individuals, and benefits from a strong tax litigation group. Dedicated practitioner and tax head Leonidas Prieto advises on corporate reorganizations and business-structure planning, as well as handling disputes with the tax authorities. Part of a broader practice that takes in M&A and project finance, Mario Gorziglia's tax focus centres on corporate reorganisations and business structuring; while Cristián Bay-Schmith (who made partner in 2018), handles tax advisory and planning, reorganisations and tax litigation. Luz María Calvo, who re-joined from the Ministry of Finance's tax policies department in November 2019, is an associate to note.
‘The firm is characterised by its close treatment of matters, as well as the support provided, from partners to the most junior lawyers. They have extensive knowledge of tax issues in Chile and the region.‘
‘Great commitment of the team to the client in terms of the work and solutions to the problems raised.‘
‘The professionals are solid from a technical point of view and with extensive experience that they make available to the client.‘
Sociedad General de Aguas de Barcelona
Entrepose and Meridiam Consortium
Inversiones La Construcción
Mall Plaza Group
Universidad Tecnológica de Chile Inacap
- Advised Chilean health insurance company Isapre Consalud on litigation with the Chilean IRS concerning the tax treatment of legal costs paid (further to constitutional claims made against the company).
- Advised Inmobiliaria ILC on the tax issues surrounding the buying, building, selling, leasing and management of the ILC Group Building.
- Advised Codelco on the tax aspects of several cross-border loans to which it is a party.
Recabarren & Asociados
Fielding a large 29-strong tax group, Recabarren & Asociados was founded in late 2014, and is highly rated for its assistance to publicly traded companies, family offices and high-net-worth individuals (HNWIs), among others. Typical work includes tax solutions for M&A, local and international reorganisations, and estate planning. The firm also fields an experienced tax litigation team that acts before the local IRS, tax courts, Court of Appeal and Supreme Court. Among the firm's six partners, HNWI-specialist Soledad Recabarren co-leads the tax consulting department alongside Álvaro Pérez (who is noted for tax structuring); while Luis Felipe Ocampo and Ignacio Iriarte co-lead the litigation and controversy group. Additional partner support on corporate and transactional tax advisory, family offices and estate planning for HNW -individuals is provided by Manuel Montero and Pablo Chechilnitzky, who also handle tax policy and personal taxes, and tax planning, respectively. Since publication the firm has hired Mauricio López Lastra and Gloria Flores from KPMG (in September and November 2020, respectively), as part of its development of a corporate finance and capital markets department.
‘The level of experience is phenomenal, and the dedication to their clients exemplary. Without a doubt they are a firm of reference and provide a complete tax advice and planning service.‘
‘The team is very good because of the combination of the experience of partners Soledad Recabarren and Manuel Montero. What makes them unique is that they really are specialists in tax matters – you don’t need second opinions!‘
‘Soledad Recabarren and Manuel Montero are people who put themselves in the shoes of their clients to understand their needs and apply the tax code.‘
‘Partners Soledad Recabarren, Álvaro Pérez and Pablo Chechilnitzky are always a phone call or text message away with first-rate response times for a complex M&A transaction or litigation.‘
‘Partner Luis Felipe Ocampo has good availability and his vision is very clear when it comes to strategy.’
Christian Democracy Political Party
- Advised the Christian Democracy Political Party on the discussion of the Tax Reform Bill presented by the Chilean Government.
The well-reputed tax practice at Allende Bascuñán & Cía is particularly noted for its advice on complex matters such as business reorganisations and associated asset sales on behalf of investment groups, as well as for representing clients before the administrative and judicial tax authorities and courts. The practice also houses a sizeable and impressive high-net-worth-families sub-practice. Largely responsible for developing the firm's tax capabilities, Francisco Javier Allende has over 30 years' tax advisory experience leads the department in conjunction with exerienced of counsel Carolina Gazitúa S. Senior associate Michael Camus D is the key contact for contentious tax matters, with associate Mario Donoso (a 2018-arrival from Garnham Abogados) provides valuable support. However, in March the practice saw the departure of former practice co-head Gonzalo Garfias, along with associates Andres Bustos and Pablo Ibánez , to establish Garfías & Cía. The firm has responded promptly, hiring Mauricio Carloza Carmona, formerly an international tax and M&A manager at Deloitte Legal Chile, in September 2020.
Other key lawyers:
‘What makes them unique is their technical knowledge and longstanding experience.’
‘They work as a team and it shows. They are very professional and listen to the real needs that one has as a client. At the same time they know how to make their problems very much their own. I really like them because they personalise the attention to the extreme and are always involved. At the same time, they have shown great capacity for ingenious solutions in countless areas.‘
‘I have had a very good experience with the firm. They are great for speed and certainty in the answers to queries.’
‘Francisco Javier Allende’s qualities are his extensive knowledge of the subject and the ability to find special solutions to unusual problems. His approach gives a lot of confidence. He and Gonzalo Garfias have two extraordinary qualities that are rarely seen in the industry – they are trained to an extremely high level and have the highest criteria when looking at issues from a broad perspective.‘
‘Of the associates, I have an outstanding opinion of Andrés Bustos. I have full confidence in his performance and especially in his professional judgement.‘
Grupo Minera Sali Hoschild
Colunquén Investments Office
- Advises Agrícola Ocoa on an ongoing basis, in relation to the tax issues surrounding the finance structure for its agricultural investments in Colombia.
- Advised Explora Chile on the tax aspects arising from it construction of a hotel in Argentina.
- Provides domestic and international tax advice to Liventus, which provides controlled and modified atmosphere technologies.
Bofill, Mir & Álvarez Jana's seven-strong department works across a range of tax-related matters, including restructuring, planning, litigation, and transactional and international tax. The group also has a high-net-worth practice active with both local and foreign families and individuals; and has a solid capability in in tax controversy matters where recent clients include Bureau Veritas and Mitsui. A specialist in taxation issues for the finance and insurance industries, Guillermo Fonseca is the group's lead partner; he has extensive experience in major cross border operations, M&A, and tax structuring. Senior associate Jorge Valenzuela is experienced in tax structuring, M&A-related tax issues, and day-to-day tax matters.
‘The firm provide a comprehensive legal and tax service to our company. The entire team have complete bi-lingual capabilities and a deep knowledge of their various areas of expertise. When we wish to execute commercial deals the team is able to provide a coordinated and complete response to any particular circumstances, and are imaginative and flexible enough to provide practical solutions to problems. They oversee all legal and tax aspects of our business and subsidiaries; we are a small company, but BMAJ treats us with complete respect as they do other clients, and are very responsive to our needs.’
‘They stand out for their knowledge of the subject, their international contacts and their relationships with other law firms in other countries. Their observations and comments on various concerns are highly accurate.‘
‘The service and knowledge of the team is outstanding. They always present different scenarios that could potentially exist and stand out for their order and methodology and presentation of solutions.‘
‘They showed full control of the situation, with deep knowledge and experience of similar scenarios.‘
‘Unlike other firms, at BMAJ senior partners and professionals work directly with us, especially partner Guillermo Fonseca and senior associate Jorge Valenzuela, who are in direct line with our advisory requirements.‘
‘The BMAJ tax team is really fantastic. They have a staff of professionals, who are specialised in the different subjects that our company requires, and they have extensive experience with multinationals. In my personal experience, the team led by Guillermo Fonseca has been, up to now, the best experience in terms of support, capacity and speed of reaction that I have had with external advisers.‘
‘Guillermo Fonseca and Jorge Valenzuela are really appreciated for their humility, accessibility and simple language when explaining complex things.‘
‘Jorge Valenzuela has deep knowledge of Chilean tax law, and is fluently conversant with aspects that touch on the international nature of our business.‘
Changshu Fengfan Power
Mitsui Mining Resources
Altis Principal Investments
Sprott Resource Holdings
Pacal Grupo Inmobiliario
Copa Chile Solar
Greenstone Venture Capital
Inversiones Fernandez Romero
- Acted for South-Korean industrial conglomerate Hyosung Corporation in a tax claim before the Chilean IRS.
- Assisted Nutrien with the tax implications of the sale of its 24% stake in SQM to Chinese corporation (Tianqi).
- Advised Changshu Fengfan Power, a Chinese manufacturer and distributor of electricity transmission and transformation line steel towers, on the tax implications of an EPC contract.
CMS Carey & Allende's six-strong tax department has particular expertise in local and international tax planning, indirect taxes (including VAT), and cross-border transactions. Other key areas are double taxation treaties, disputes, and acting for HNW individuals and families. The practice evidences particular industry experience in the energy, financial services, food and beverage, and hospitality sectors. Practice head Diego García is a tax planning and corporate restructuring expert, who is ably supported by senior consultant Cristóbal Groetaers.
Grupo Inso Chile
Inmobiliaria del Inca
- Advised Grupo Inso Chile (a consortium consisting of Inso, Condotte and Cossi) on the tax structure for a tender bid for a hospital design and construction contract.
Deloitte Legal Chile
A steady market presence advising international and domestic companies, international investors and HNW individuals, Deloitte Legal Chile is widely respected for its assistance with day-to-day tax issues, as well as the tax aspects of M&A and investment transactions. The practice also acts in tax disputes. Joseph Courand has over 22 years' professional experience, and is primarily focused on transfer pricing, international tax planning, tax-related M&A matters and international reorganisations. Other key tax partners are Hugo Hurtado (promoted to lead partner in May 2020), Transactional tax specialist Paula Osorio and younger partner Cristián Meneses whose broad experience includes particular expertise in corporate and labour taxation.
Fontaine & Cía
At medium-sized, multi-service law firm Fontaine & Cía, the tax team's main clients are from the real estate and construction sectors. The group's advice focuses on personal and corporation tax structures, VAT, IRS resolutions, property tax, and the tax issues surrounding dispositions. The department co-heads are experienced partners Hernán Fontaine Talavera and Astrid Hardessen Lazo, with key support provided by associates Javier Cortés and Soledad Lavín. The firm recently formed a strategic alliance with boutique firm Brzovic & Cía. Abogados, which is dedicated to tax issues.
Sociedad Concesionaria Tunel El Melon
Compañía De Seguros De Vida Chilena Consolidada
Cámara Chilena De La Construcción
Mutual De Seguridad De La Camara Chilena De La Construcción
Mitjans & Valdivieso Group
Maui & Sons
- Successfully acted for Ciudad Empresarial in a tax matter before Chile’s IRS and tax courts, which meant the cancellation of surtax and return of paid taxes.
The seven-strong team at Garnham Abogados advises primarily on the tax aspects of investments and transactional operations, and is co led by Arturo Garnham and Patrick Humphreys Garnham focuses on income tax, the tax aspects of M&A, and on legal structures for high-net-worth individuals, along with tax litigation; and Humphreys noted for his tax advisory work involving private wealth, as well as corporate tax issues (including corporate reorganisations). Support at senior associate level is provided by Andrés Lopez (corporate tax and HNWIs) and Catalina Concha (corporate and transactional tax matters.
‘They know a lot about tax issues and most importantly, they are up to date with what is being discussed, and can plan what is best for the client, assessing the risks and benefits.‘
‘They have extensive knowledge of tax law. This is a subject that can be very difficult for other people to understand, but they know how to explain the laws very well. I think that only a person who masters a subject 100% can easily explain something very difficult. They also have a broader view of problems and their solutions.‘
‘They are very professional and dedicate time and passion to what they do. Each case is the most important one and they care about the client behind the case, so that the client feels welcomed and protected. They go beyond simple resolution of the conflict.‘
‘They are people who are tremendously involved in understanding what the client wants to achieve, and what are the difficulties and advantages. They also always see the big picture. In other words, they always try to go beyond the problem that is presented to them in order fully to understand what they want to achieve and what the long-term objectives are.‘
‘Patrick Humphreys and Arturo Garnham stand out.‘
Asociación Nacional de Fútbol Profesional
- Providing the Asociación Nacional de Fútbol Profesional with tax law advice in relation to Chilean IRS processes.
Garrigues Chile's six-strong tax department is co-led by30-year veteran Oscar Ferrari and higly experienced counsel Sebastián Ferrer del Valle; both focus primarily on corporate tax planning and tax litigation. The team also specialises in real estate issues, mainly involving VAT and income tax; and it regularly advises resident and non-resident individuals on personal and inheritance taxes. Associate support is provided by María Jesús Hidalgo Larraín, who joined from Philippi Prietocarrizosa Ferrero DU & Uría in July 2019 and focuses on corporate tax planning, particularly for restructurings; and Juan Pablo Obaid, whose practice is centred on tax litigation.
‘We like them for their preparation, technical and practical knowledge, and prudence.‘
‘This is an excellent team of tax attorneys, and what makes them stand out above the rest is their additional knowledge in commercial and corporate law aspects, giving a truly comprehensive vision of matters.‘
‘Oscar Ferrari stands out for his tax knowledge, as well as his understanding of business and other branches of law.‘
Administradora General de Fondos SURA
Arroyo Energy Group
- Assisted Deris and Friosur with the tax planning and structuring for the sale of Salmones Friosur (salmon division) to Agrosuper.
- Advised Matco Armacero and Ingeniería e Inversiones on the tax planning for their acquisition of Aza Participações, the owner of steel company Gerdau.
- Advised Scania on the tax planning for the incorporation of a special purpose vehicle so as to participate in a public transport tender.
Tax Advisors' 10-strong group is highly experienced in tax litigation before the Chilean IRS, tax courts, appeal courts and the Supreme Court. The practice also assists with tax planning, compliance, and tax matters involving family businesses. Christian Blanche Reyes is a recognised expert in corporate and family tax planning, and the tax aspects of re-organisation strategies and M&A; while fellow partner Benjamín Bernstein stands out for family and labour tax planning matters. Senior associate Felipe Scolari (tax structuring, planning and litigation) is another key figure; and the team was further strengthened with the hire of associate Víctor Galilea, who joined from Cruzat, Vicuña, de Larraechea Abogados in August 2019.
‘Tax Advisors is a consolidated team with great experience in tax planning; its strong point is the solid preparation of its partners and the comprehensive vision they have of the Chilean tax system. In addition, they have the advantage of knowing not only the rules and circulars but the criteria that Chile’s IRS uses to apply them, which most tax advisers do not. This gives clients a lot of security in the legal advice, which is not merely theoretical but with a solid base of experience from many years of professional practice.‘
‘Its great plus is being a boutique office where clients receive the advice they seek directly from the partners in a timely and personalised way.‘
‘Christian Blanche Reyes and Benjamín Bernstein are recognised in the Chilean tax legal environment for their experience, knowledge and strategy when facing tax problems and constantly changing legislation. They are benchmarks for judges as they teach at the Chilean Judicial Academy and are relevant legislative advisers on legal changes.‘
Established in late 2018, Torretti & Cía.'s 10-strong team advises investment banks, HNW individuals, corporations and non-profit organisations on the tax aspects of matters ranging from foreign investment and corporate law to private clients and wealth management. Name partner Eduardo Torretti is highly respected in the Chilean tax market and handles tax planning, structuring and litigation; while Sebastián Martínez-Conde's practice includes advising on the tax efficiency of investment structures, and tax disputes. Francisco Alcaíno provides support at senior associate level and Isidora Henríquez is also a key member of the team. Moreover, the firm continues to grow: despite losing an associate to the Ministry of Finance, it made three new hires in 2019, and further strengthened the team in July 2020 with the arrival of semi-senior María Elena Würth from Deloitte Legal Chile.
‘It is a very competent, personalised service. They manage, as a team, to make you feel that you are their most important client, and they compare favourably with other teams but are much more diligent.‘
‘Great for its agility and strong knowledge of tax problems. It is an excellent working group.’
‘The team is exceptional; they are very professional and know what they are doing worldwide.‘
‘The Torretti team has the great advantage of mixing solid technical knowledge in matters of international taxation with the soft skills required for managing HNW clients. Undoubtedly, this team stands out for putting the client at the centre and for being able to deliver personalised attention.‘
‘Eduardo Torretti is very complete and with a very powerful commercial focus, which, complemented by his technical knowledge, makes him a very complete tax lawyer.‘
‘Sebastián Martínez-Conde and Eduardo Torretti stand out for their quick and practical approach to clients’ problems. They are proactive advisors and strategic partners in their clients’ businesses, rather than mere second-line consultants or support.‘
‘Sebastián Martínez-Conde is very proactive. He is a lawyer, who knows what he is doing. Sebastian always goes beyond what clients are looking for and has the solution or the technical explanation needed. Although he is young, he has a lot of experience.‘
- Assisted ICC Biotech with the tax aspects of its corporate restructuring.
- Assisted US-based global technology company ThoughtWorks on tax optimisation issues.
- Advised Spain’s Cox Energy on a range of matters, including capital gains and international reorganisation issues.
At Ulloa & Cía, the 11-member department's key tax areas include domestic and international tax consultancy, corporate restructuring-related tax issues, and tax dispute resolution, along with family business tax matters and specialised tax compliance. Founding partner Nicolás Ulloa is a former PricewaterhouseCoopers Consultores, Auditores y Compañía Limitada partner; his practice includes tax litigation and compliance, international taxation, local tax consultancy and corporate restructurings, along with family office and HNW matters. Adriana Zaidan leads the firm's international tax law department, and handles inbound and outbound cross-border tax structuring and financing, intercompany transactions and day-to-day tax issues of local subsidiaries. Senior associate Domingo Godoy is focused on. assist clients in issues related to local tax matters and corporate law, including corporate restructuring and tax-payer defence.
‘This is a very prepared and united team, with highly integrated partners who directly participate in each matter.‘
‘A very professional team, with responsible and knowledgeable experts in tax matters.‘
‘Highly compliant, responsible lawyers with continuous availability for the client.‘
‘Nicolás Ulloa and Adriana Zaidan have extensive knowledge of tax matters, with the excellent ability to generate new ideas and impressive memory of each case.‘
Baker McKenzie Chile
With extensive experience of the technology, finance, pharmaceutical and mining industries, among others, Baker McKenzie Chile fields a five-strong team led by the highly experienced partner Alberto Maturana, who specializes in international tax and tax planning. Clients also benefit from the practice's expertise in the tax aspects of complex cross-border and multi-jurisdictional transactional matters. Key associate Alfonso Mora handles domestic and international taxation, including tax planning for M&A, transfer pricing and tax issues applied to the digital economy and banking and finance. However, former associate Sebastian Coloma left for Spoerer y Valdés in July 2019, while associate Alfonso Mora has taken leave of absence to complete an International Tax LLM at Maastricht University.
- Advised Fundación Atenna on the tax planning for the co-production of an art project for the Chilean pavilion at Venice’s 2019 Biennale.
The five-member team at Cariola Díez Pérez-Cotapos has been particularly active, recently, in tax dispute matters, including audit procedures, as well as representing clients proposing amendments to Chile's recent tax reform bill. The practice also advises local and international clients on a daily basis, and assists with the tax structuring of M&A and finance deals. A partner since 2018, and recently appointed director of the International Fiscal Association's Chilean branch, Javier Cerón leads the tax practice. The practice group was strengthened in November 2019 with the arrival of semi-senior María Paz De Carcer from Pereira Covarrubias Montes Abogados.
‘Cariola… but especially Javier Cerón, who is a lawyer very committed to the objectives of IBM, quick to respond and with a general point of view of the business and the expected solution. Compared to other firms, they provide a personalized and superior service.‘
‘Availability, quick response, finished technical knowledge. Javier Cerón is an outstanding partner and Brian Bustos is a committed and efficient associate.‘
DNB Nor Bank
Pontificia Universidad Católica
Automatic Data Processing
- Assisted Fundación Dunas de Cachagua, a non-profit organisation, with a challenge to real estate tax (charged on land that is applying for nature sanctuary qualification).
- Successfully acted for Unión Española in relation to real estate tax, which was charged by the Chilean IRS on a soccer stadium.
- Advised Joyvio on the tax aspects of the acquisition of Australis Mar.
DLA Piper Chile regularly provides tax support for M&A and project finance deals, including new areas such as e-commerce and fintech. It also advises on, compliance, double taxation treaties and transfer pricing, as well as frequently representing clients before Chile's specialised tax courts (TTA). Rodrigo Álvarez heads the tax group and maintains a broad practice including inbound and outbound matters, complex tax structuring, tax planning, tax compliance, primarily across the real estate, financial services and technology sectors, and for family offices. Senior associate-level support comes from German Vargas (tax planning and restructuring, the tax aspects of M&A transactions and due diligence, taxation in cross-border transactions, audit procedures and VAT issues).
‘DLA Piper’s attorneys, in tax matters, are characterised by their up-to-date knowledge, and they propose simple, clear solutions and alternatives, which are in compliance with current regulations and doctrine. Furthermore, they are always attentive in their answers.‘
‘Rodrigo Álvarez and senior associate German Vargas show high technical qualities and a very thorough knowledge of the industry in which we required their services.‘
‘Rodrigo Álvarez is very analytical and pro-business.‘
- Advises Uber on the tax planning surrounding the development of its operations in Chile.
Grasty Quintana Majlis & Cia.'s five-member department focuses on legal tax compliance (including representation before Chile's IRS during tax auditing procedures); and international, inheritance, corporate and individual taxation, along with VAT. It is also active in the tax structuring of M&A transactions and tax litigation. Tax compliance and planning specialist Mónica Justiniano (tax compliance and planning, corporate reorganizations, and commercial and corporate law), leads the tax group, which includes experienced associate Felipe Errázuriz (tax and corporate advisory, including corporate reorganizations).
‘Mónica Justiniano has excellent technical and pragmatic knowledge.‘
Mar Adentro (Family Office of the Hurtado Berger family)
Guerrero Olivos' practice focuses on tax regulatory matters and M&A-related tax issues, as well as assisting HNW individuals and foreign corporations with tax compliance, and undertaking the defence of tax claims before Chile's IRS and special tax courts. Partnership-level involvement comes from corporate all-rounder Pedro Pellegrini provides leadership at partner level, with senior counsel Alejandro Chechilnitzky (who arrived from EY -where he was a senior manager- in July 2019, taking over leadership of the practice following the January 2020 exit of former senior associate and tax group head José Miguel Prieto left to establish Prieto Tax & Legal. In addition to permanent tax advice, Chechilnitzky focuses on national and international taxation, structuring and reorganisations, and corporate tax planning (both domestic and cross-border); since publication he has been appointed partner - effective Februrary 2021.
Chile Pacific Foundation
Santiago Metals Limitada
GLL Real Estate Partners
- Advised BCI Bank on several tax matters, including tax structures for investments into the US.
The unwinding of its 2018 tie-up with Ried Fabres saw Jara del Favero Abogados revert to its former independent status in early 2020. The firm's small team punches above its weight due to the expertise of veteran tax specialist and practice head Rafael Valdivieso, who focuses on commercial and tax law, M&A and tax structuring for individuals, businesses and economic groups; and the design and implementation of reorganizations. The team also handles tax planning, compliance and disputes; and was further strengthened in November 2019, by the arrival of Martín Hudson who joined as a senior associate from Barros & Errázuriz.
Exportadora El Parque
Olivares de Quepu
Familia Gonzalez Palacios
- Advised Curifor on the tax issues surrounding the creation of subsidiaries in order to develop its real estate business.
Larrain y Asociados Abogados fields a three-member tax team led by Víctor Manuel Avilés, a former Vice President of the Chilean Institute of Tax Law, whose practice is focused on tax planning and tax litigation. Associates Manuel Larrain and Gonzalo Guerra complete the group, for which tax litigation and audits conducted by the Chilean tax and customs authorities are key areas; it also has experience in tax structuring and compliance.
Letonja Abogados Tributarios
Founded in 2017, Letonja Abogados Tributarios is a tax law boutique tax that handles day-to-day tax issues, reorganisations, estate and tax planning, and tax litigation for clients from across the energy, telecoms, port, construction products, engineering and media sectors, among others. The ten-strong firm houses a mix of lawyers and chartered accountants, and fields two experienced partners, namely: Alexander Letonja (tax consulting, corporate reorganisations and tax litigation); and Kristofer Letonja (tax planning and defence work).
‘It is a team at a high professional level, with advanced knowledge in the matters on which they advise and with adequate answers and great technical foundation.‘
‘The team is very well prepared, responds quickly and is reliable.‘
‘Partners Alexander Letonja and Kristofer Letonja both have great capacity, professionalism and prompt responses, as well as great experience and expertise.‘
‘They are highly professional and have great knowledge of tax law, and the partners give a lot of personalised attention.‘
Cía. Industrial El Volcán
Tresmontes Lucchetti Group
Televisión Nacional de Chile
Emasa Equipos y Maquinarias
Centrales Hidroeléctricas de Aysén
- Advised ANACSA’s shareholders on the tax issues surrounding the sale of the company.
Morales & Besa's tax practice is involved in most of the firm's transactions, including project finance, capital markets and M&A. The team also assists with general tax and compliance matters, along with administrative and legal representation before the tax authorities. Experienced partner Eugenio Besa, and counsel Gracia Curtze constitute the core of the team following the departures of former of counsel Francisca Pérez and senior attorney Jaime Rosso (to join TMF Group and Quadrant Abobgados, respectively). Curtze focuses on advising corporate clients and family offices in connection with transactional, financial and accounting matters; she has particular expertise advising international companies on investment issues.
‘Compared to other Chilean firms with which we have worked, Morales & Besa is very reactive, answering clients’ requests quickly and practically, and addressing problems effectively. This attention differs significantly from other law firms in Chile, with which we have worked in the past.‘
‘Dedicated to achieving a proper understanding of what the client requires and agile in the preparation of strategy and definition of critical points, it is a high-level team and highly focused on compliance.’
EIG Global Energy Partners
The Republic of Chile
- Assisted Sumitomo Mitsui Banking Corporation and Banco Santander-Chile (as lenders) with the VAT financing surrounding a wind farm project.
Puente Sur Tax Advisory
At full-service tax and accounting firm Puente Sur Tax Advisory, tax head Ignacio Gepp has over 10 years' experience in tax matters. A partner since January 2020, Gepp is the legal face of a team comprising predominantly economists and chartered accountants, and which specialises in corporate tax, tax structuring of M&A transactions, audit procedures, and transfer pricing-related litigation.
‘Great knowledge of the law with first-class customer service.‘
‘Ignacio Gepp is very clear in his ideas and a skilful communicator – one of the best professionals around for tax matters.‘
Hitachi Data Systems
Alberta Investment Management Corporation
Zarhi Dreyse Amar was founded in 2018 by Rodrigo Zarhi Hernández, Ramón Dreyse Dañobeitía and Carlos Amar Grez, all formerly of Edwards & Cía. The team provides tax planning and advisory a client roster comprised primarily of HNW individuals and families, as well as handling estate planning and tax structures for diverse industries - including agricultural, forestry, mining, financial - and commercial businesses. the service offering also includes assistance with tax restructuring and family business transactions and sales.
‘The truth is that very meticulous work is done, studying the variables of each line of business in our companies, always taking into account the individual issues of each case. The firm’s main strengths are its experience in the various deals they have carried out, as well as the creativity and speed in executing actions in record times. I think its main differential is the ability to customise and search for solutions beyond the obvious.‘
‘The main strengths that differentiate them from other firms are their updated knowledge of the national tax legislation, the speed in capturing solutions to problems posed, and being a medium-sized firm there is direct contact with the partners. They also don’t have the bureaucracy of some larger firms.‘
‘When compared to other tax firms, Zarhi Dreyse Amar Abogados clearly understands our needs and requests. It is necessary to highlight their commitment and clarity in processing and applying our needs, unlike their competitors who do not take the time to know our company deeply, so as to deliver and provide us with the best defence tools.‘
‘We have had a very good impression of this firm’s commitment, knowledge and application of the best strategy in resolving our company’s tax legal issues.’
‘Rodrigo Zarhi Hernández is able to develop a deep understanding of the client’s personal situation and offer creative solutions that are compatible with the family’s reality and protect our heritage in the long term.‘
‘I recognise Ramón Dreyse Dañobeitía for his availability and creativity in solving problems. He is highlighted for his knowledge (theoretical and practical) of tax matters; versatility and flexibility in finding creative and well-founded solutions to problems that are difficult to solve, as well as direct involvement in client issues with quick responses to requirements.‘
‘Ramón Dreyse Dañobeitía stands out for his great ability to structure solutions that are not always obvious but that his experience and ability allow him to assemble in a safe and ethical way in record time.‘
- Advised Colliers International on tax studies regrding the the sale of expendable real estate assets belonging to Scotiabank and Copec.