Tax in Guatemala

Alta QIL+4 Abogados

The 'expert' and 'very experienced' team at Alta QIL+4 Abogados has notable strength in local and cross-border tax matters, advising on the tax aspects of multi-jurisdictional M&A and financial transactions, as well as tax restructuring, compliance, transfer pricing and the tax issues relating to setting up new businesses. The team also handles contentious matters, representing clients in litigation before the courts and tax authorities and in complex tax investigations. Practice head José Quiñones is experienced in advising foreign financial institutions on the tax aspects of bond offerings, M&A and project finance transactions. He receives strong support from senior associates Otto Ardón, who regularly advises regional corporations on the tax aspects of restructurings and acquisitions, and Hellen Guerra, who has particular expertise in tax planning and transfer pricing issues.

Practice head(s):

José Quiñones

Testimonials

‘The advice is of the highest level. As a client, we feel supported and very well advised at all stages of the transaction.’

‘The entire team are experts and very experienced. I would like to highlight José Quiñones for his availability, effort, practical approach and focus on results.’

Key clients

Telus International

Daimler

Henkel

Abbot Laboratories

Pay Pal

Credit Suisse

Banque Cantonale de Geneve

Macquarie Bank

AmBev

Alimentos Quaker Oats y Compañía

Work highlights

  • Defended a leading agribusiness conglomerate against a criminal complaint filed by the local tax authority alleging tax fraud.
  • Acting for a major tobacco company in a dispute over an administrative ruling by the local tax authority relating to the procedure for tax adjustments.

Consortium Legal

The ‘excellent‘ team at Consortium Legal draws on the firm’s presence throughout Central America to advise on multi-jurisdictional tax matters, including the tax aspects of M&A transactions. The team also advises on transfer pricing and tax planning, and represents clients in disputes with the tax authorities. Among its clients are local, regional and multinational companies from the financial, non profit, manufacturing, agroindustrial and mining sectors. Alfredo Rodríguez is experienced in advising on the tax aspects of corporate transactions, including M&A and private equity investments, as well as advising high-net-worth individuals and family groups on estate and succession planning. He co-heads the team with the experienced Olga Meléndez and David Erales, who leads the tax litigation practice. Associate Alejandra Fuentes-Pieruccini is noted for her advice on transfer pricing and international taxation. Since publication, the team has been rejoined by Mario Archila, previously head of his own practice at Archila & Asociados.

Practice head(s):

Alfredo Rodríguez; Olga Meléndez; David Erales

Testimonials

‘An excellent team with a very good grasp of tax matters. They give constant feedback and good advice when required.’

‘They are always fully available to help, and work directly with clients, so they feel like part of the team. David Erales’s service is truly comprehensive.’

‘They stand out for their knowledge, capability, professional and ethical attitude, availability to clients and excellent interpersonal relationships.’

Key clients

United Airlines

Cemex Guatemala

Alapar

Banrural

Bantrab

Grupo Multi Inversiones

Grupo Farmagua

Grupo PDC

Grupo Bac-Credomatic

Cinepolis Guatemala

Walmart

Milésimo

Grupo Sur

Banco Industrial

Work highlights

  • Advised Grupo PDC on the tax aspects of the leveraged acquisition of the Australian Dairy Goods business in Guatemala and El Salvador and of the operations of Dizac, one of the main distributors in El Salvador.
  • Advised a Guatemalan group of investors on the tax matters relating to the acquisition of Absortex, which produces and distributes diapers, feminine hygiene products and other hygiene supplies.

Mayora & Mayora, S.C.

The Guatemalan member of Lataxnet, a network of Latin American firms focused on tax and transfer pricing, and with additional offices in El Salvador and Honduras, Mayora & Mayora, S.C. is well placed to handle Central America-wide tax issues. The ‘exceptional‘ team advises on tax planning, transfer pricing, customs issues, indirect taxation and tax-related disputes. Its clients include a wide range of companies from the banking, construction, food and beverages, technology, energy and telecoms sectors. Led by the highly regarded Eduardo Mayora, the team includes ‘standout‘ partner Juan Carlos Casellas, who has notable expertise in tax litigation, and senior associate Juan Carlos Foncea, who is experienced in advising Guatemalan and international companies on tax planning and cross-border tax issues.

Practice head(s):

Eduardo Mayora

Testimonials

‘Mayora & Mayora’s expertise in aeronautical tax matters makes it exceptional.’

‘Juan Carlos Casellas is always aware of the different legislative changes and the possible effects that they may have on our industry. In addition, he is very available and expresses himself fluently.’

‘Both the client service and the performance of the lawyers in our tax lawsuits has been brilliant. Juan Carlos Casellas is truly an exceptional guy and very knowledgeable on the subject. They are far above the rest of the offices we have worked with.’

‘They stand out for their attention to clients and knowledge of the issues. Juan Carlos Casellas is a standout.’

‘What makes the firm stand out is that the lawyers are not only specialists in tax matters, but also have knowledge of the needs of their clients, so they can give personalised and tailored advice. This firm, in our opinion, stands out above others.’

‘They establish personal relationships with clients and the commitment of the team is outstanding. This makes a very important difference in relation to other competitors. The firm’s main qualities are the deep knowledge of the subject, leadership, commitment, customer service, and the passion demonstrated by partners such as Eduardo Mayora and Juan Carlos Casellas.’

‘Juan Carlos Casellas stands out for his knowledge of tax law in administrative and judicial processes.’

Key clients

Banco Industrial

Cindu de Guatemala

Ingenio Palo Gordo

GBM de Guatemala (IBM)

Bolsa de Valores Nacional de Guatemala

Gas Natural Fenosa Telecomunicaciones Guatemala (UFINET)

Anixter International

Euro-Funding Multilateral Projects

Isotron

Archila & Asociados

Tax litigation boutique Archila & Asociados acts for large domestic companies and multinationals from a broad range of sectors, including construction and real estate, software development, automobiles, food and beverages, and agroindustry. The team focuses on defending its clients in disputes with the tax authority, and recently it has been particularly active in litigation against the customs administration over import taxation. In addition, the firm offers a non-contentious practice which advises on tax compliance policies and structures and tax planning. Since publication, Mario Archila has departed to rejoin the tax practice at Consortium Legal.

Testimonials

‘They are very well known by the tax administration, and often when they appear on cases the tax administration does not pursue the matter.’

Key clients

Radio Televisión Guatemala

Televisiete

Spectrum

Plantaciones Minar

Floricultura

Vistas Pradera

Urrea Constructores

Desarrollos San Jose

Energuate

Asociación de Azucareros de Guatemala

Corporación Multi-Inversiones

Cofiño Stahl (Toyota)

Asociación de Importadores de Vehículos

Asociación de Importadores de Motocicletas

Esso Guatemala Servicios (Exxon-Mobil)

Transequipos (Rover)

Grupo Introsa

Seguros Mapfre

PepsiCo

Grupo Tecún

NCO Star Comunicaciones Guatemala

Inversiones y Bienes del Atlántico

Sonido Seguro

Grupo Almo

Ternium

Spectrum

Reserva Oakland

Servicios Educativos Centroamericanos

Vistas Pradera

Central Agrícola

Bandegua

Grupo Ferroso

Tableros de Aglomerado

Innovacycle Guatemala

Importadora Jaeger

Postforming

Ferromax

Work highlights

  • Acting for steel manufacturing and export company Ferromax in litigation with the customs administration over import taxes.
  • Acting for recycling company Innovacycle in litigation over import taxes.
  • Acting for Importadora Jaeger in litigation relating to import taxes.

Arias

Arias has been particularly active recently advising on customs tax issues, as well as advising technology companies on the growing area of digital services taxation. The team acts primarily for multinationals operating in Central America, often advising on cross-border issues alongside the firm’s other offices in the region; its areas of strength include the retail, oil and gas, logistics and BPO sectors. In addition, the team advises on the tax aspects of financial, M&A and real estate transactions and draws on its strong litigation department to handle tax disputes. An increasingly established figure, practice head Ximena Tercero is experienced in transfer pricing and international trade matters, and is a key member of the firm’s pro bono practice. Associate Elisa Lacs is noted for her customs law expertise.

Practice head(s):

Ximena Tercero

Carrillo & Asociados

Advising multinationals with operations in Guatemala on tax planning is a key area of strength for the team at Carrillo & Asociados, which also advises on the tax aspects of corporate transactions and customs and import tariff issues, and assists foreign and Guatemalan ultra-high-net-worth clients with estate planning and international tax matters. On the contentious side, senior associates Ricardo Recinos and Fernando Mendizábal have expertise in tax disputes. Founding partner Alfonso Carrillo, who has experience in complex, cross-border tax matters, and Rodolfo Alegria, who advises major Central American companies on tax planning and the tax aspects of M&A and restructurings, lead the team. Senior associate María de Lourdes Villanueva brings additional expertise in customs and international trade issues and cross-border tax structures to the team. Since publication, Alegría has left the firm after more than 30 years, moving to Estudio Chávez Bosque as of March 2022.

Practice head(s):

Alfonso Carrillo

Key clients

Datum

Syngenta

Nestlé Guatemala

Assa Abloy Guatemala

Olam Agro

Tubex

Work highlights

  • Acting for software company Datum in a dispute with the tax authority over the payment of income tax.
  • Assisting agrochemicals production and distribution company Syntenga with the tax issues associated with changes to its value chain in Central America and the Caribbean.
  • Defending Nestlé Guatemala against a criminal complaint brought by the tax administration over alleged customs fraud.

A. D. Sosa & Soto

Juan Pablo Ortiz, who has notable past experience as general counsel to the Guatemalan tax administration, co-heads the practice at A. D. Sosa & Soto, which has recently seen an increase in work advising on compliance with local and international tax regulations and strategic tax planning. The team also advises on transfer pricing, the tax aspects of corporate and real estate transactions, and tax-related disputes. Practice co-head Einar Klanderud focuses on tax litigation.

Practice head(s):

Einar Klanderud; Juan Pablo Ortiz

Testimonials

‘Juan Pablo Ortiz has experience in the public and private sectors and is able to deal with and understand client’s problems in a comprehensive way, without biases.’

BLP

As a full-service firm, BLP is able to draw on the strength of its corporate and finance departments to assist clients with various tax issues, regularly advising national and international companies on the tax implications of setting up operations in Guatemala and investing in local companies. In addition, the team advises on administrative processes and audits conducted by the tax authority. Practice head María Inés Arenales handles the tax structuring of corporate and financial transactions, and senior associate Rogelio Muñoz is experienced in tax compliance and due diligence.

Practice head(s):

Maria Ines Arenales

Key clients

Tata Accesorios Globales

Lafrancol Guatemala

HCL

Eversheds

Atco Espaciomovil

Versatec

Dole

Centrorent

Ceva Logistics

Huntsman

Work highlights

  • Advised Tata Accesorios Globales on various tax matters, including defending the client in tax and customs litigation and assisting with strategic transactions and their tax implications.
  • Advised pharmaceuticals manufacturer Lafrancol Guatemala on the tax implications of different restructuring scenarios.
  • Advising BPO and technology company HCL on special tax regimes under which the company can be registered, making its operation more tax-efficient.

EY Law Central America

With offices throughout the region, EY Law Central America is well placed to advise clients on tax issues in Central America and the Dominican Republic. The team assists with due diligence and tax structuring for M&A transactions, transfer pricing and tax compliance, and has seen recent growth in tax controversy work. Its client base includes companies from the agroindustry, telecoms, real estate, consumer products, energy and financial services sectors. Costa Rica-based Rafael Sayagués leads the team with Manuel Ramírez, who focuses on international tax and the tax implications of corporate transactions.

Practice head(s):

Rafael Sayagués; Manuel Ramírez

Testimonials

‘Good knowledge of our business and tax issues.’

‘The team stands out for its understanding of tax law and ability to defend us.’

Sfera Legal

Sfera Legal regularly advises on corporate and individual tax planning, procedures for the refund of tax credits and compliance with Guatemalan tax regulations, as well as handling tax and customs-related litigation. Managing partner Ignacio Andrade Aycinena leads the team, while founding partner Jorge Asensio Aguirre is also a key figure in the practice. In addition, senior associate Luis Enrique Solares is highly experienced in administrative and judicial tax proceedings. Associate Marta Alonzo acts in tax and customs disputes.

Practice head(s):

Ignacio Andrade Aycinena

Testimonials

‘Ignacio Andrade and Marta Alonzo are standout individuals.’

Key clients

Telecomunicaciones Celulares – Tigo

ADM

Grupo Tir