Tax in Chile
Baraona Fischer & Cía's wide-ranging practice covers ongoing advisory issues; the tax aspects surrounding corporate matters, M&A and financings; and transfer pricing. Other areas of strength include estate planning and tax litigation. The team acted for Cooperativa Agrícola Lechera against the Chilean IRS' assessment that gains obtained from regular operations are taxable income. It also assisted EuroAmerica with the tax structuring of the sale of the clients' life insurance businesses and long-term savings operations in Chile to Zurich Insurance Group. Alex Fischer, Isabel Espinoza, senior partner Juan Manuel Baraona, Carolina Collantes and Juan Cristóbal Ortega are all highly rated; the tax-compliance team is led by Boris León.
Barros & Errázuriz's 'team synthesises tax complexity and comes to efficient and proactive solutions'. It is highly rated for its structuring of major domestic and international transactions as well as tax litigation, planning and due diligence; and the firm has launched a sub-department, which assists US Citizen clients with US Foreign Account Tax Compliance Act compliance issues. The client list includes Agrosuper, British American Tobacco Chile, Calzada Capital Partners, Colbún, and Constructora Socovesa, which the team successfully defended against a Chilean IRS tax claim in the Supreme Court. In transactional highlights, the team advised Caitan, a joint venture between Mitsui & Co and Técnicas de Desalinización de Aguas, on the tax aspects surrounding the construction financing for a desalination plant. Fernando Barros, Carola Trucco and María Teresa Cremaschi are highly rated, and Mauricio Bascuñán and Evelyn Sepúlveda are experienced senior associates; 'Trucco and Sepúlveda are excellent resources and navigate complex structures with ease and proactivity'. Tomás Kovacevic left the firm for Chile's Treasury Ministry.
Carey's 'responsive, thoughtful, connected and practical tax team', which includes in-house certified accountants and an economist, is widely respected for tax consulting, tax planning, due diligence, audits and litigation. Active clients include MetLife Compañía de Seguros, Brookfield, Air Products, Sencorp, Barrick, HSBC and Chilquinta Energía. The team recently advised an alternative asset management company on the tax aspects surrounding the sale of subsidiary companies, and assisted a gold mining company with complex VAT issues. It also acted for an international manufacturing company on the tax side aspects of its acquisition of shares in a chemical company. Managing partner Jaime Carey and Jessica Power co-head the tax group. Senior associate Manuel Garcés and associates Daniela Pfeffer and Ximena Silberman are also key to the team.
KPMG in Chile fields 'reliable tax experts who are knowledgable and have a good understanding of clients' business'. The scope of practice includes domestic and international tax advisory work, tax disputes, corporate and labour-related tax, and expatriate tax services. Other areas of focus are transfer pricing, transactional tax services -including tax due diligence- and acquisition structuring. Francisco Lyon is the lead tax partner and Rodrigo Stein 'has good knowledge of tax law, gives practical advice and helps clients take informed decisions'; other highly regarded partners are Mauricio López, Andrés Martínez and Alberto Cuevas. Director Gloria Flores and tax manager Juan Infante are also widely respected.
Deloitte Legal Chile is highly regarded for its expertise in tax advisory matters, M&A and investment-related tax issues, and tax dispute resolution. Typical clients include international and domestic companies, international investors and high net-worth individuals. Tax practice head Joseph Courand is the lead international tax group partner. Other key advisers include domestic and international tax expert Hugo Hurtado, M&A tax specialist Paula Osorio and Jose Ignacio Concha; Cristián Meneses was made partner and David Lagos left the firm.
Ernst & Young (Santiago)
Ernst & Young (Santiago) is a multinational professional services firm that fields experts in tax planning, compliance, and tax litigation; it also advises on the tax aspects of transactions and complex wealth management issues. Team head Pablo Greiber is a highly rated tax law expert, Alicia Domínguez is well known for her assistance with mining sector-related tax issues, and transactions specialist Macarena Navarrete is country managing partner.
Philippi Prietocarrizosa Ferrero DU & Uría is highly focused on complex domestic and international corporate and private-wealth matters, tax planning and structuring, tax compliance and transfer-pricing services, and tax-related M&A; the practice is also well known for tax litigation and administrative procedures before the tax authorities. Clients include VISA, LATAM Airlines Group, Isapre Cruz Blanca and Banco Bilbao Vizcaya Argentaria (BBVA); Guillermo Infante led tax advice to the latter on the indirect acquisition by Scotiabank of a majority stake in Banco BBVA Chile. Mario Silva is also highly rated and Arturo Selman is the senior associate to note; former practice director Patricio Silva-Riesco left the firm to establish his own consultancy.
PricewaterhouseCoopers Consultores, Auditores y Compañía Limitada
PricewaterhouseCoopers Consultores, Auditores y Compañía Limitada is highly rated for its assistance with international taxation and the tax side of financing, M&A and restructuring. The global, multidisciplinary firm's Chilean branch is also experienced in advising on compliance issues, transfer pricing and tax litigation. The practice has several highly regarded advisers, including Francisco Selamé, Sandra Benedetto and Loreto Pelegrí.
Allende Bascuñán & Cía 'has incredible depth, with clear and accurate advice delivered quickly'. The practice regularly advises on the tax aspects of business reorganisations and company sales; it also assists with international tax advisory matters and defends taxpayers before the tax authorities and in courts. The team recently assisted Explora Chile with the tax structuring of its investments in the Argentine hospitality sector. Francisco Allende heads the tax practice; Gonzalo Garfias is 'focused, considered and incredibly astute', and senior associate Andres Bustos is 'one to watch - his relationship skills and eye for detail are exemplary'.
Baker McKenzie Chile's team is led by Alberto Maturana, who specialises in international tax and tax planning for corporate, M&A and foreign investment transactions; the group also advises on tax audits and other administrative matters involving the tax authorities. Alfonso Mora and Sebastián Coloma are the associates to note.
Cariola Díez Pérez-Cotapos advises on the tax aspect of acquisition structuring and the restructuring of existing investments; the team has also developed particular expertise in the tax rules affecting financial institutions and has a robust tax litigation practice. The team recently acted as tax adviser to Goldcorp in relation to a joint venture project with Barrick involving one of the largest undeveloped gold deposits in the world; IBM, Rabobank and Rolls Royce Marine Chile are also clients. Javier Cerón is the principal contact.
Claro & Cia.'s tax practice assists with complex domestic and cross-border transactions, tax efficient structuring and the implementation of tax efficient schemes; it also assists with audits and litigation. In a recent mandate the team advised Chilean paint and coating company Pinturas Tricolor on the tax aspects of its intra-group corporate reorganisation. Jorge Carraha heads the tax department and Nicolás Maturana is an experienced senior associate.
CMS Carey & Allende's tax strengths include domestic and international tax planning, and assistance with VAT, indirect taxation and cross-border transactions; the team also includes experts in double-taxation treaties and tax planning for high net worth individuals and families, and represents clients before the tax authorities. Key clients include Sun Dreams, Enagás, Europastry, Sonda and Charles Taylor InsureTech. Diego García P is in charge of the tax group and senior associate Cristóbal Groetaers is also well regarded; former senior associate Gastón Gallegos moved to Carey in August 2018.
Prieto Abogados 'stands out because of its approach towards clients, taking the time to understand their needs'. The practice is experienced in the tax issues surrounding investments into the energy, ports and public utility sectors; the team also advises on project finance-related tax matters, tax-planning for family offices and individuals, and tax litigation. It recently assisted Transmisora Eléctrica del Norte with the VAT aspects of the construction of an electricity transmission line. Mario Gorziglia, Leonidas Prieto and Cristián Bay-Schmith are the main advisers; Rosario Vidal is the associate to note.
Tax Advisors 'combines knowledge of tax matters with deep experience of dealing with the Chilean IRS'. The firm's practice ranges from ongoing tax advisory work, tax-related M&A and transfer pricing, to tax planning and tax litigation. In recent matters, the team assisted ANFP (Chile's football federation), with a tax analysis of its corporate structure that included income and VAT issues. Christian Blanche Reyes and Benjamín Bernstein are 'experienced tax experts who can deal with complex issues, particularly in an environment where the law and tax regulations can change every year'.
Bofill, Mir & Álvarez Jana's broad practice includes tax structuring for cross-border transactions and it has particular expertise in mining, construction and financial services sector-related matters. In recent contentious work, the team defended Mitsui & Co against the Chile's IRS in relation to tax deductible interest payments. Guillermo Fonseca is team head and Paris Norambuena, who joined from EY Chile, and Jorge Valenzuela B are experienced associates.
Cabello & Cia.
DLA Piper (Chile) advises on tax law issues across a wide range of sectors and has been assisting its clients with tax matters that arose further to the Chilean Government's recent tax reform. Other matters include advising Uber Chile on the tax issues surrounding the development of its operations in Chile. Rodrigo Álvarez is the key contact; Miguel Zamora left to join Chile's IRS.
Fontaine & Cía
Fontaine & Cía's 'excellent team' has developed a particular niche acting for clients from the real estate and construction sectors where the country's most recent tax reform has caused increasing complexity. The practice undertakes ongoing tax advice, reorganisations and associated tax consulting, international taxation, administrative tax litigation ad tax reports. Department co-heads Hernán Fontaine Talavera and Astrid Hardessen Lazo have been overseeing considerable growth of the practice: 2018 saw the firm incorporate senior and junior associates Maria Soledad Lavin (formerly at EY) and Francisco Castrillon. More recently, as of May 2019, the team was further reinforced by the arrival of tax specialists Franco Brzovic and Magdalena Brzovic as part of a strategic tie-up with Brzovic & Cía Abogados.
Fuensalida & Del Valle Abogados
Tax boutique Fuensalida & Del Valle Abogados was founded in 2014 and 'combines impeccable legal knowledge with a business-oriented approach'. Recent work included advising Banco de Crédito e Inversiones, the third largest bank in Chile, on the tax issues surrounding the acquisition of Walmart Chile's credit and financing business. Team head Jaime Del Valle is 'an extraordinary attorney who provides in-depth tax analysis together with creative business solutions'.
Garnham Abogados' 'service is delivered within expected timeframes and fulfils client expectations'. The practice includes corporate tax, private wealth tax, income tax and M&A-related tax issues. It also assists with tax structures for high net worth individuals, international tax planning, transfer pricing, VAT, tax litigation and estate planning. Arturo Garnham and Patrick Humphreys are the names to note.
Grasty Quintana Majlis & Cia. is primarily focused on legal tax compliance (including tax auditing procedures), VAT, inheritance, international taxation, corporate income, and individual taxation; the practice is also active in M&A tax structuring. Mónica Justiniano leads the group and Felipe Errázuriz is an experienced associate.
Guerrero Olivos' senior associate José Miguel Prieto leads the tax group. The practice advises on M&A-related tax advice, and assists higher net worth individuals and foreign corporations with tax compliance issues; it also defends IRS tax claims and advises international funds on the tax structuring of their investments in Chile. Clients include Andean Tower Partners, Banco Santander and Santiago Metals.
Jara Del Favero & Ried Fabres's Rafael Valdivieso is the tax department's lead partner. The team advises both Chilean and international companies on tax-related reorganisations, tax planning for individuals and business groups, as well as the tax issues surrounding corporate transactions and natural resources-related project finance.
Morales & Besa's tax practice covers matters including tax planning, litigation and compliance, as well as other IRS-related administrative matters, but has a particular focus on foreign direct investments and cross-border project finance in the energy and infrastructure sectors. Recent work included assisting EIG Global Energy Partners and its Chilean affiliates with the tax aspects of project and financing agreements. Francisca Pérez is 'an excellent lawyer and tax expert', and Jaime Rosso is a key senior associate; former senior associate María José Becker S moved in house as general counsel of Ferrovial (Chile).
Torretti & Cía. was established in October 2018 by Eduardo Torretti and Sebastián Martínez-Conde -formerly CorreaGubbins tax partner and senior associate, respectively. Both 'make themselves available and revert quickly' and clients speak of 'a great team that is very business focused'. The pair recently assisted Toesca with the tax aspects surrounding a shopping mall acquisition from Principal Financial Group. Other clients include Korn Ferry, Softland, Agustinas Servicios Financieros, Ibereólica Renovables and Grupo Caral.
Ulloa & Cía's 'excellent team is very professional and personally dedicated to its clients'. The practice's key areas are domestic tax consultancy and tax-related corporate restructurings, international tax consultancy, tax compliance, tax disputes, and family business and governance. Nicolás Ulloa and Adriana Zaidan are the names to note.
Urenda, Rencoret, Orrego y Dörr is experienced in tax litigation, the tax aspects of corporate reorganisations and cross-border transactions, tax planning, and day-to-day tax assistance; the team also assists with private wealth and advises local and foreign companies on tax issues involving employees and expatriates. Gonzalo Rencoret is the key contact.