Next Generation Partners

Tax in Guatemala

Alta QIL+4 Abogados

Alta QIL+4 Abogados’s strengths lie in advising major multinational clients on the tax aspects of cross-border transactions, in addition to handling high-profile tax litigation, drawing on the experience of the firm’s considerable corporate and dispute resolution departments. In the latter respect, the team is well versed in litigation against the tax authority regarding a variety of issues. Key areas of expertise include transfer pricing, capital gains on international transactions, compliance issues and sensitive tax investigations. Experienced practice head José Quiñones advises on tax issues stemming from international corporate and financial transactions, as well as compliance matters. Associate Otto Ardón has expertise in assisting regional conglomerates with tax issues relating to restructuring and expansion into new markets, as well as transfer pricing and fintech tax matters.

Practice head(s):

José Quiñones

Key clients

British American Tobacco


Revive Guatemala

Grupo Gentera

Telus International

Abbott Laboratories

Frito Lay/Quaker Oats


Maquinas Exactas

Work highlights

  • Advised Mexican microfinance group Grupo Gentera on the tax issues relating to the transfer of the credit portfolio of its local subsidiary to Fundación Génesis Empresarial, a not-for-profit entity.
  • Acted for Comercializadora Campbells in litigation against the tax authority, seeking the reimbursement of export value-added tax.
  • Acting for Naturaceites in litigation relating to the adjustment of tax on profits.

Consortium Legal

Consortium Legal stands out for its expertise in tax litigation, where the practice was further strengthened in June 2021 with the arrival of highly experienced litigator Mario Estuardo Archila from tax boutique Archila & Asociados. In addition to handling administrative and judicial tax disputes, the team advises regional and multinational companies on the tax aspects of international transactions and tax structuring. Co-heading the practice with Archila are the ‘highly respected’ Alfredo Rodríguez, who has expertise in advising individuals and family groups on estate and succession planning; Olga María Meléndez, a renowned advisor in the banking, aviation, mining, telecoms and food and beverages sectors; and litigation specialist David Erales, who is singled out by clients for his ‘extensive knowledge of Guatemalan jurisprudence and tax issues’. Associate Alejandra Fuentes-Pieruccini frequently supports in international and local tax matters.

Practice head(s):

Alfredo Rodríguez; Olga Meléndez; Mario Archila; David Erales


‘Constant updates and a personalised service from the partners.’

‘David Erales stands out for his extensive knowledge of Guatemalan jurisprudence and tax issues.’

‘Alfredo Rodríguez’s real expertise in various fields of law makes him a highly respected figure in both the public and private sectors, and it is difficult to find a lawyer with a similar profile.’

‘The strength of the team lies in the ability to understand the client’s needs and provide advice based on the law applicable to their specific case.’

‘The firm’s attorneys possess a high degree of integrity. They carry out their work based on what is legal and what is correct.’

Key clients



Banco de los Trabajadores


Banco Industrial


Grupo Cofiño Stahl


United Airlines

Grupo Tecún


Radio Televisión Guatemala


Desarrollos San Jose

Asociación de Azucareros de Guatemala

Asociación de Importadores de Vehículos

Inversiones y Bienes del Atlántico


Asociación de Importadores de Motocicletas

Fresh del Monte

Work highlights

  • Adviced Millicom on the tax issues relating to its acquisition of 45% of the shares of Tigo Guatemala to gain total control of the company and its operations.

Mayora & Mayora, S.C.

Local and international tax planning is a key area of expertise for Mayora & Mayora, S.C., which is able to draw on its membership of the Lataxnet alliance of Latin American firms when focusing on tax and transfer pricing issues in the region. The practice assists its client base with complicated tax situations and defending against taxes levied illegitimately. The broad offering also covers tax aspects of cross-border transactions, customs and international trade issues, VAT, transfer pricing and tax-related litigation. Practice head Eduardo Mayora is renowned for his strength in tax-related matters and counts the National Stock Exchange of Guatemala among his clients. Juan Carlos Casellas has ‘extensive experience’ in tax litigation and transfer pricing matters. Senior associate Juan Carlos Foncea is part of the cross-border tax team and has a focus on customs and international tax matters.

Practice head(s):

Eduardo Mayora


‘Mayora & Mayora has a very long history in the field of tax advice. We have had a cordial relationship for more than 50 years.’

‘Juan Carlos Casellas stands out for his extensive experience and academic training.’

‘Juan Carlos Casellas supports us in tax cases and has knowledge of tax laws and the actions of the tax administration.’

‘Mayora advises us on defence against the tax administration in Guatemala. We already have 15 years of working with Mayora and we feel comfortable.’

Key clients

Banco Industrial

Cindu de Guatemala

Ingenio Palo Gordo

Bolsa de Valores Nacional de Guatemala

Pochteca Guatemala

Elevadores Otis


Consolidados 807

Refractarios Nacionales (Morgan Thermal Ceramics)

Work highlights

  • Assisted Pochteca Guatemala with challenging the tariff treatment classification of sodium imported from the US by the Superintendence of Tax Administration (SAT).
  • Defended Elevadores Otis against adjustments made to the income tax due for 2018 by the SAT, which sought the payment of tax on dividends.
  • Advised Consolidados 807 on tax issues that arose after the client received imported fabrics that had been intended for delivery to its Costa Rican subsidiary.


The ‘committed’ team at Arias acts in contentious and non-contentious tax matters for its multinational client base that has representation in a range of sectors, including oil and gas, digital services and pharmaceuticals. The team is well known for its advice on the tax aspects of high-profile international M&A and restructurings, as well as its assistance with related compliance issues and transfer pricing. Drawing on the expertise of the firm’s highly regarded litigation department, led by Mario René Archila, the team also handles significant tax disputes with the Superintendence of Tax Administration. Ximena Tercero heads the tax group with support from associate Elisa Lacs, who specialises in customs matters. Both are praised by clients as ‘exceptional lawyers’.

Practice head(s):

Ximena Tercero


‘Arias’s team in Guatemala is committed to the client. They not only provide a high-quality service but understand our company culture. Arias has a centralised service, which allows for the creation of synergies with other countries where they provide services and we require legal support. This saves time and maintains the same standard for all the countries where they provide us with services. In terms of billing, there is a single point of contact for all countries, which greatly facilitates communication.’

‘What I like the most is that the team’s legal opinions are clear, educational and explanatory.’

‘Elisa Lacs and Ximena Tercero are both exceptional lawyers. They are very professional, but above all diligent and precise, and search for options within the law that resolve any doubts that may arise. 100% recommended. Their work and personalised service in customs and administrative matters has helped us a lot in improving and understanding the processes that are required in this country.’

‘They have strong leadership that allows for timely follow-up on clients’ queries and requests.’

A. D. Sosa & Soto

A. D. Sosa & Soto’s tax practice handles a range of contentious and non-contentious matters, with particular strength in tax planning and compliance matters. The team is experienced in advising international clients on tax planning relating to their operations in Guatemala. It also represents clients in administrative and judicial tax disputes. Practice co-head Juan Pablo Ortiz is noted for his expertise in transfer pricing, cross-border tax structuring, and compliance, while Einar Klanderud, his partner in leading the department, focuses on international tax matters.

Practice head(s):

Einar Klanderud; Juan Pablo Ortiz


BLP’s tax practice is bolstered by the strength of its corporate and finance departments in Guatemala, and its network of offices throughout Central America. The practice advises major multinational clients on the tax aspects of regional M&A, business expansions and corporate reorganisations. In addition, the team assists clients with significant tax and customs-related litigation and handles due diligence processes. Practice head María Inés Arenales brings additional expertise in banking, corporate and insurance matters to her advice on tax structuring. She is assisted on the gamut of matters by associate Rogelio Muñoz.

Practice head(s):

María Inés Arenales

Key clients

3Pillar Global

Grupo Orbis (Pintuco)

Grupo Santillana

Operador Logístico Ransa

HH Global

Papa John’s – Drake Food Service

Banco Promerica Guatemala

Tata Accesorios Globales


HCL Technologies

Work highlights

  • Advised 3Pillar Global on tax issues relating to its expansion into the Guatemalan market.
  • Advised Papa John’s on the tax aspects of the sale of its franchise in Guatemala to a Chilean company.
  • Acted for Banco Promerica Guatemala in a dispute with the SAT over the adjustment of the income and value-added tax paid in 2014.

Carrillo & Asociados

Carrillo & Asociados regularly represents regional and multinational companies in complex tax litigation and audits, but also has an established practice advising ultra-high-net-worth individuals on international tax and estate planning. In addition, the team advises on the tax elements of corporate transactions, customs and import tariff issues, and corporate tax planning. The practice is led by managing partner Alfonso Carrillo, while senior associate María De Lourdes Villanueva is noted for her expertise in tax planning, litigation and customs matters. Previous practice co-head Rodolfo Alegría joined Estudio Chávez Bosque S.A. in March 2022.

Practice head(s):

Alfonso Carrillo

Key clients

Super Vitaminas


Olam Agro Guatemala

Nokia Operations de Guatemala

Operadora de Tiendas

Chiquita Guatemala

Work highlights

  • Representing Super Vitaminas, a company operating a foreign franchise in Guatemala, in a long-running criminal investigation being conducted by the SAT relating to an audit of the client’s main suppliers.
  • Acting for Datum in a challenge to adjustments made to the income tax and value-added tax owed by the client in 2013 and 2014.
  • Advised on the distribution of an estate that included assets left in a foreign trust.

EY Law

EY Law Central America leverages its connection to the global consultancy firm and its regional network to counsel clients throughout Central America. The team has notable expertise in advising on the tax aspects of cross-border M&A and corporate reorganisations, compliance and transfer pricing, and also has a growing tax controversy practice. Rafael Sayagués and Manuel Ramirez, who focuses on international taxation and the tax aspects of corporate transactions, lead the team from the Costa Rican and Guatemalan offices, respectively.

Practice head(s):

Rafael Sayagués; Manuel Ramírez


‘The team stands out for the accessibility, availability, communication skills and professional approach of its lawyers.’

‘Manuel Ramírez makes communication easy.’

Sfera Legal

Representing clients in litigation with the Superintendence of Tax Administration (SAT) is a key area of activity for the tax practice at Sfera Legal, which handles disputes over tax adjustment claims by the SAT, in addition to criminal tax evasion and customs fraud cases. The team’s workload also covers advice on transfer pricing, compliance with customs procedures and the refund of tax credits. Managing partner Ignacio Andrade Aycinena is noted for his expertise in tax litigation, while founding partner Jorge Asensio Aguirre is also a key contact. Associate María Elena Vásquez is also recommended by clients. Since publication, Andrade has left the firm, effective as of October 2022.

Practice head(s):

Ignacio Andrade


‘Sfera Legal and its team in Guatemala have the ability necessary to represent their clients in all kinds of procedures related to the tax administration. Our full trust is placed in them as our external legal advisers.’

‘The team’s main strength is simple: they are always attentive and available to support their clients. This continuous support, especially from Ignacio Andrade and María Elena Vásquez, makes us feel confident.’

Key clients

Telecomunicaciones Celulares – Tigo


Grupo Tir