Tax in Mexico
Chévez, Ruiz, Zamarripa y Cía SC
Broadly considered a market leader, Chévez, Ruiz, Zamarripa y Cía SC is especially strong in contentious work but also covers consultancy and administrative work, namely transactional consulting, regulatory matters, corporate risk prevention related to anti-money laundering and anticorruption, service concession agreements, costumers rights and responsibilities, relevant financial issues, and ultra-high-net-worth and social security services. An institution, the firm was founded 35 years ago as with a focus on accountancy and, having expanded into legal consultancy 20 years ago, now straddles both areas, with offices in Mexico City, Monterrey, Querétaro, New York City and Madrid; and a workforce of about 400 practitioners - of which half handle legal work. The firm suffered some losses in previous years, being the first port of call for corporate legal firms looking to build their tax practices (although in May 2019 Ana Sofía Ríos joined the team from Creel, García-Cuéllar, Aiza y Enríquez, S.C. ) and has since sought to diversify its offering, opening a transactional practice led by the experienced Miguel Valle, and as of September 2019, a labour consultancy and litigation practice led by Rafael Vallejo , both formerly at González Calvillo, SC. Tax matters remains the core of the firm at present, however, where key practitioners include practice head Manuel Sáinz, Alejandro Torres, and Ricardo Cervantes , who each have over 25 years’ experience in the sector and handle disputes; César De la Parra, who has 16 years of litigation and tax controversy experience; Daniel De la Parra, who leads the firm’s anti-money laundering practice; transfer pricing specialist Ricardo Rendon; René Meza, who is known for his tax planning work and specialises in M&A and cross border transactions as well as capital markets expertise; Raul Navarro Becerra, who handles tax planning, with a focus on international transactions and expertise in energy, restructuring and trusts; and former Director General for International Treaties at the Ministry of Finance, Armando Lara, whose specialisations include international taxation (including BEPS) and treaty-related work. Also noted are Pablo Corvera, who is especially known for handling financial matters; Eudenio Franzoni and César G Meraz, managing partners of the Querétaro and the Monterrey offices, respectively; New York office managing partner, Eduardo Valenzuela; and non-lawyer Samy Lazarov, who covers wealth management and estate planning. Since publication the firm has announced three new partners as of January 2020: Rodrigo Farias (tax advisory and litigation), Pedro Aguilar (local and international taxation), and Gibran Hazar (strategic litigation and regulatory matters).
At Creel, García-Cuéllar, Aiza y Enríquez, S.C. the 24-strong, standalone tax practice follows the firm’s overall line, handling high-end matters, mostly dedicated to tax within the realm of M&A, financial services, projects and debt and equity capital markets, working for publicly traded and private funds engaged in private equity, real estate, infrastructure and energy, also handling transfer pricing (focused on transactional and high-value work), social security, and wealth planning, as well as representation before tax authorities. The individual lawyers are unanimously praised for the quality of their work: practice head Alejandro Santoyo assisted RLH Properties in the tax structuring of the $500m acquisition of all the shares and interests that OHL holds in the companies that own the Rosewood Mayakoba Hotel, the Banyan Tree Mayakoba Hotel, the Fairmont Mayakoba Hotel, the Andaz Mayakoba Hotel and the Golf Course “El Camaleón” Mayakoba, following an initial acquisition; Jorge Correa advised Howard Energy Partners on the tax matters related to the refinancing of the Nueva Era pipeline project through the issuance of 6.05% senior notes, valued at $470m; Omar Zúñiga acted for KKR on tax matters in connection to the $385m acquisition of Quadion / Minnesota Rubber and Plastics, a global leader in the manufacturing of rubber and thermoplastic components and assemblies; and Luis Vázquez successfully represented an international client operating in the mining and minerals sector in a case before the administrative court, relating to a corporate tax assessment. Counsel Eduardo Michán is also recommended. Since publication the firm has moved to further deepen the practice, hiring Luis Rodrigo Salinas Olvera as counsel in January 2020; formerly at PRODECON, the state entity for the protection of tax contributors, his practice centres on tax disputes and litigation. Other departmental clients include Cornershop, Promecap Acquisition Company, Lexington Partners, Trinity Investments, Oaktree, and Walton Street.
Clients and peers alike value Baker McKenzie Abogados, S.C.’s ‘strong, solid and experienced’ tax team, which, with over 70 lawyers, is one of the largest in the country, providing national coverage from five offices across the country and backed by the firm’s international network. With a focus on the oil-and-gas, automotive, manufacturing and financial sectors, the practice has been busy handling the direct and indirect tax issues affecting companies operating in Mexico, such as the tax authorities’ new approach to BEPS in auditing taxpayers; permanent establishment and transfer pricing adjustments for foreign companies; maquila programmes; the tax implications of the energy reform legislation; and tax disputes. A highlight was its advice to Syneos Health on the aspects of merging several of its Mexican subsidiaries, including the application of tax treaties to avoid double taxation. The ‘very capable, experienced and resourceful’ Luis Carbajo heads the practice and handles tax assessments and tax litigation; Jorge Narváez acts on tax controversy, consultancy and transfer pricing; and Héctor Reyes undertakes tax planning, M&A transactions and corporate tax matters, including tax compliance issues. Ulises Castilla is also recommended and specialises in financial-sector matters and litigation. Other names to note include Roberto Cardona and Ciudad Juárez-based Juan Valles.
Clients trust Basham, Ringe y Correa, S.C. because of the ‘size and depth’ of the team, the ‘excellent service’, and the ‘close and personal relationships’ the lawyers build with clients. Moreover, the lawyers ‘always seek solutions without losing a sense of the client's requirements’. With a group of 28 practitioners that includes five partners (who share departmental leadership), the relatively large practice covers the full range of tax matters, with a focus on representing clients before the relevant authorities and in disputes, combining tax with the firm’s strong international trade and customs capabilities. The practice advised Toyota on VAT matters related to the importation of technology and equipment for the development of its assembly plant in Guanajuato; assisted a Mexican tool manufacturing company with a successful request for the return of various tax balances in favour of VAT following a lengthy process involving an audit and a denial of the request by the Mexican tax authorities (SAT); and -also successfully- represented Eli Lilly in a dispute against the SAT following the latter’s rejection of a $10m deduction related to marketing expenses. Alejandro Barrera is ‘exceptional: his advice is always insightful’, and he is also highly rated for his international tax expertise; Victor Barajas has ‘outstanding knowledge and understanding of clients’ needs’; Gerardo Nieto is considered ‘one of the best litigators’; Gil Zenteno is ‘very experienced’; and Sergio Barajas is also recommended, as is ‘very responsive and reliable’ associate Norberto Ruiz. Operating from the firm's offices in Mexico City, Monterrey, Querétaro and León, the practice counts Aeromexico, Herbalife, Volkswagen, IMM Research México (Immunotec), Sandvik , British Columbia Investment Management, Tesa Tape México, Sumitomo Corporation (Serviláminas), and Tresmontes Lucchetti México among its clients.
Ernst & Young
The ‘very solid’ Ernst & Young is considered the ‘best and most active of the Big-4’, and as housing a ‘very very good tax litigation team’. Like the other major auditors, as well as tax boutiques, it suffered some loss of practitioners to the explosive growth of tax departments at full-service firms over the last five years or so, but it retains its place in the upper echelons of the market. In addition to its tax litigation expertise, the practice is also particularly strong on international taxation, although it covers the full range of tax matters. The firm maintains tax pratiotioners in 16 offices across Mexico, with Monterrey, Merida and México City constituting the main hubs. Standout names among the practitioners include: in litigation, Nora Morales, considered by one peer as ‘the best tax litigator in Mexico’, and ‘tax litigation monster’ Enrique Ramírez Figueroa; support in this area comes from Manuel González and Antonio del Campo, the latter having previously worked as head of contentious matters for major contributors at the SAT. In tax consultancy, Manuel Solano heads the tax and legal services department and, being dual qualified, works between New York and Mexico City; working alongside him, Koen van’t Hek heads the international tax services, Elias Adam Bitar heads the private clients’ practice, and Alfredo Alvarez the energy segment for Mexico and Central America (he too divides his time between Mexico City and New York). Nadja D Ruiz is another name to note.
The August 2018 arrival of transactional tax specialist Federico Scheffler from SMPS Legal re-stated Galicia Abogados S.C. commitment to tax matters; the subsequent mid-2019 hire of Edson Uribe Guerrero (formerly deputy prosecutor general at PRODECON), as the practice group's third partner deepens the bench still further and firmly establishes the department's stand-alone profile. The now 17-strong practice group, which has 'great technical capabilities and an exceptional relationship with clients', handles consulting and litigation and demonstrates a focus on transactions in the financial, infrastructure, real estate, private equity and regulated industry sectors where the firm is a leading player. Recent mandates saw the team active on operations in the energy sector, such as advising Fortress Investment Group and International Finance Corporation on the tax aspects of the development of their respective renewable energy plants. In other work, the firm acted for key client Grupo Bimbo on several matters, including pension fund structuring, compliance, and legal and tax audits of production plants; and Cabify, on a corporate restructuring following a business acquisition, as well as on day-to-day matters. Practice head Gabriela Pellón is ‘growing into the role of leading the practice’ and her 'engagement and dedication are first class'. Other names to note include senior associates Denise Lester (who leads on litigious matters) and Gabryela Valencia (consultancy), and associates Alejandra Paniagua, Fernando Luján and Arturo Portilla. 2019 also saw experienced litigation associate Nayely George join from Ortiz, Sosa Y Asociados, S.C.. Since publication, Ms. Lester has been raised to the partnership, effective January 2020.
According to one source Ritch, Mueller, Heather y Nicolau, S.C. fields a ‘very talented team of tax professionals with practical experience who go above and beyond from a client service perspective’. Like in the other large full-service corporate firms, the 15-strong team of lawyers and accountants is known especially for its transaction-related work (particluarly its strong sectoral focus in energy), although it does also handle day-to-day matters, contentious work and tax planning. Recent mandates saw the practice group advise Equinor (formerly Statoil) on the tax aspects of its investment structure in Mexico as part of its participation in the National Hydrocarbons Commission concession bidding rounds, including on its consortium with BP Exploration Mexico and Total E&P Mexico; and it represented the EVM Energía group in structuring its joint venture with General Electric to develop an 850MW greenfield combined-cycle power plant, involving private placements and loans amounting to $740m. In real estate, another sector in which the practice has been active, it advised Thor Urbana on the acquisition of the Marina Town Center, a 45,000m² marina complex, and the incorporation of a long-term holding structure for the investment that will allow for a tax-efficient divestment in the future; and CCLA, a $300m CIM Gp / Compass Gp joint venture on the structuring and implementation process of investment in Mexico to develop and operate purpose-built, multi-family, rental-residence buildings across Mexico’s largest cities in partnership with GIC, Singapore’s sovereign wealth fund. At the helm of the practice is Oscar López Velarde, ‘a trusted and competent tax advisor who, given his past experience, adds a practical approach to resolutions and planning matters’; working alongside him Santiago Llano Zapatero is also recommended; key support comes from senior associates Juan José Paullada Eguirao and Santiago Díaz Rivera, and associates Alonso Miranda Barceló and Diego Hernández Barrios. Other clients include Glencore, EXI/MIP, Grupo Diavaz, Acciona, Hines HRM Investor, G500 and Amundi Asset Mangement.
Tax boutique Turanzas, Bravo & Ambrosi has endured the loss of some younger lawyers over the last few years, as the development of the tax practices at full-service firms saw them seek to recruit practitioners from already established specialist firms and the Big-4. The practice remains, however, a ‘very reputable and sophisticated’ market reference, acting primarily on transactional tax matters. A recent work highlight involved assisting Puente Aéreo Corporación with the tax aspects of its $29.1m sale, through LATAM Airlines Group, of a 39.5% stake in air cargo carrier MasAir to Discovery Americas. In other work, the firm handles tax litigation, representation before the tax authorities, international taxation, wealth management, and international trade and customs. The group has seven partners. Standing out among them are the ‘very solid and experienced’ Mauricio Bravo, who handles corporate, indirect, and local and international taxation, tax litigation and estate planning; the ‘super’ Pedro Ramírez, who is highly regarded for his wealth management work; and Angel Turanzas Díaz, who is involved in the direct-sales sector but also covers oil-and-gas matters, wealth management and representation before tax authorities. The other key practitioners are Mauricio Ambrosi who covers tax litigation, international taxation (particularly in relation to the marine and transportation industries and the pharmaceutical sector), and consultancy relating to transfer pricing; Jorge Fuentes, who represents clients in tax litigation and before the tax authorities; Carl E Koller, who covers corporate and international taxation, tax planning for foreign direct investment and financing and tax consulting for private equity and variable return securities, along with litigation; and Francisco Ortega, who provides advice on corporate tax and representation before the tax authorities, as well as coverage of direct sales matters (a segment in which the firm has deep expertise).
Arias y Meurinne, SC
The 16-strong team at Arias y Meurinne, SC is especially strong in litigation matters, including in cases that involve international taxation issues, such as double taxation conventions and national provisions with international effect, although it does also handle consultancy work, including transfer pricing and estate planning, for an impressive client roster in the telecommunications, automotive and pharmaceutical sectors. The practice group litigated cases representing contingencies of over $2bn over the course of the year, with highlights including successfully acting for an international telecoms company in a case arguing the unconstitutionality of article 42-A of the Federal Fiscal Code (which enables the tax authorities to request information outside of an official tax audit or inquiry without any guidance as to what it can do with the collected information); and in another case applying a 0% VAT rate to international roaming charges to international operators. In other mandates, it assisted a client with regard to a tax audit concerning a divestiture, and with a major overhaulof its payroll system in order to comply with new income tax and VAT regulations regarding payments to employees. Name partner Pedro Arias Garrido is a highly recommended litigator, while Luis Eduardo Meurinne handles planning and consultancy; Leobardo Brizuela joined the firm in September 2018 - he was formerly head tax litigator at Grupo Salinas; while Humberto Rodríguez left in March 2018 to establish his own firm. Other key names include Salvador González Escamilla, Pamela Orozco, Omar Isaac Molina, and senior associate Leah Sánchez.
The ‘knowledgeable’ team at Garrigues ‘has grown to become a relevant player in the Mexican legal market’. The practice was strengthened with the arrival of Manual Llaca and a team of four tax litigation lawyers from KPMG in May 2019, bringing the number of team members to ten. The group specialises in M&A, tax planning and international tax issues related to double tax treaty application; it can also call on the firm's international network in what is it's very much its core practice. In recent work it assisted Edenred Group and Alicorp enter the Mexican market; Cerealto Siro Foods with analysis of the tax consequences and impacts of a re-financing process (involving withholding tax issues and a foreign tax credit controversy related to the financing structure); Autovía Nuevo Necaxa-Tihuatlán (AUNETI) and its shareholders Globalvia and ICA, with analysis of the legal grounds, tax merits and impact of a debt restructuring process; and Aicox Soluciones subsidiary Alternativas Renovables México, with the validation and re-filing before the Mexican tax authorities of a VAT-refund request that had previously generated a controversy. The ‘very talented and trustworthy’ practice head Santiago Chacón is valued for his knowledge and experience; key support comes from senior associates Ricardo Fernández de Arellano (tax disputes, and tax planning for corporates - especially in the healthcare sector), and Diego López Vargas (tax advice for foreign companies expanding into Mexico, tax planning for corporate restructurings and M&A, and value supply chain transformation projects). Other clients include Viscofan, JC Decaux Group, Latam Logistics, Enertis Solar, Idai Nature, ECG Ingeniería, Windstream Services and Ágora Europe.
Jáuregui y Del Valle, S.C.’s tax team is ‘always informed about the latest news and potential for reform, helping clients anticipate and prepare for change’. Mainly focused on providing consultancy work for real estate funds, it advised CKD Walton II on the tax aspects of the structuring of the platform to issue $300m B-series certificates, and on the structuring of a joint venture for development of the $150m La Mexicana residential project located in the Santa Fe area of Mexico City; CKD Walton on the $188m acquisition of the JW Marriott hotel located in the Polanco Area of Mexico City; and PGIM Real Estate on the restructuring of its retail fund in order to allow investors to continue obtaining a tax exemption in Mexico. In other work, the team also handled litigation and representation before the authorities, as well as additional domestic and international tax matters, including issues related to finance, banking, telecoms, strategic alliances, corporate reorganisations, international trade and insurance. Managing partner Luis Gerardo Del Valle Torres (who is also know for his welath management advice) is recommended; he co-leads the practice with Eduardo Medina Zapata ; between them they cover the full range of tax matters and lead on all mandates; senior counsel Luis Carballo Balvanera is another key practitioner; support comes from Gonzalo Mauricio Breña Labarrère and Jessica Paz González, and associates Josemaria Ferez Gil and Ricardo David García Robles. Other clients include FINSA Real Estate Managament, FINSA CFD II, and FIBRA Terrafina.
Respected by peers, Rodrigo Gómez heads the practice at Jones Day, which handles transactional tax matters, tax planning and restructuring, audits, administrative and regulatory procedures, and permits and authorisations; the group can also call on the firm’s wider international network. Recent highlight work included the tax apsects of Grupo Aeropuertario de la Ciudad de México's $6bn issuance of four bond seroes under Rule 144A / Reg S, as part of the tender offer to re-purchase up to $1.8bn bonds; General Electric's $160m sale of the industrial business of its Power Conversion division to Wolong Electric Group (including tax advice regarding the Mexican tax effects of the sale of the Mexican subsidiaries of said industrial business); and Grupo Gigante on an amendment to its existing syndicated credit agreement for the purpose of refinancing the payment terms. Support comes from associate Andrés Lieja . Other clients include Lixil Group / American Standard, The Haskell Company, Methode Electronics, Dream Hotel Group and Crédito Real.
Nader, Hayaux y Goebel, SC 'is always ready to help no matter what. The lawyers are always looking for new and creative ways of adding value. They become friends and not only tax or legal advisors, and they spend several hours understanding the business in order to provide top-level service’. The relatively small team -now four-strong- handles the tax aspects of high-end transactions and projects, including M&A and capital markets (including CKDs, ETFs and Fibra Es), as well as day-to-day tax matters and those relating to the recent reforms in the Mexican energy sector. The team advised Caisse de dépôt et placement du Québec (CDPQ) on a tax due diligence and on structuring the acquisition of a portfolio of companies which includes both the operator and the concessionaire of the Circuito Exterior Mexiquense; Desarrollos Delta on the structuring and placement of its first, real estate-focused CKD for an aggregate amount of MXN$2.35bn; and the investors and the manager of EMX Capital in connection with the Mexico-related tax implications arising in Mexico (and elsewhere) as a result of the MXN$1.246bn divestiture of its participation in Autotransportes El Bisonte. Practice head Adalberto Valadez sets its culture: ‘what makes this practice unique is the knowledge and creativity of the leader of its tax practice, and his leadership within his team’; he is ‘the best tax advisor for deal structuring, with immense knowledge of bilateral and foreign treaties with Mexico’. Key support comes from associates Alejandro Gordillo and from Fernanda Mateospayró, who joined in October 2018 from Foley Gardere Arena. The firm's commitment to the practice and its growth was further demonstrated in July 2019 with the hire of Ángel Escalante Carpio from his own firm, as a partner, significantly deepening the bench; his practice extends into IT&C and AML matters. Other clients include Artha Capital, Banyan Tree, BlackRock, DILA Capital, General Electric and CKD Infraestructura México.
Ortiz, Sosa Y Asociados, S.C.
The ‘experienced and professional' boutique firm Ortiz, Sosa Y Asociados, S.C., has impressive accounting and tax expertise, its coverage including tax consultations, transactional tax advice, valuations and optimisation, legislative guidance, dispute resolution and representation before the tax authorities. Clients appreciate the ‘closeness and attention lawyers show each case’, their ‘availability and versatility’ and their ‘international outlook’. In recent highlights, the team advised Grupo Financiero Interacciones on the tax aspects of its merger with Grupo Financiero Banorte; and Banco Invex on the tax aspects of its MXN$808m acquisition of Credomatic de Mexico, a subsidiary of BAC International Bank. The fourteen-strong team is led by accountants Miguel Ortiz and Ignacio Sosa and lawyer Luis Curiel, the principal legal practitioner at the firm; key support comes from associate Eduardo Lalieu; other names to note include lawyer and accountant José Manuel Trueba. However, associates Antonio Rosas Estrada, Juan Jose Diaz Rivera and Eduardo Lalieu left to establish Diaz Rivera, Lalieu, Rosas, S.C. in August 2019.
The 18-strong team at Sánchez Devanny has ‘outstanding knowledge of international tax matters’, and demonstrates both ‘ownership and involvement’ of the cases with which it is entrusted, and ‘strong continuity, allowing long term cooperation with knowledgeable and in-the-know members. This is particularly helpful with procedures that take years to complete'. Bringing 'its own initiative and creativity’, the team provides federal and cross-border tax consulting services for inbound infrastructure projects and a broad array of industries including manufacturing, real estate, hospitality, retail, automotive, aerospace, transportation, mining, power, oil and gas, food, health and life sciences, as well as outbound cross border tax advice to Mexican companies expanding globally. Its capbilities cover both contentious and non-contentious matters, including tax treaty interpretation, transfer pricing and foreign tax credit transactions; tax investigations; information exchange, simultaneous audits and mutual agreement procedures regarding multilateral transactions and transfer pricing; wealth management and estate planning. The team is co-led by four partners: Ricardo Leon-Santacruz in Monterrey, Abel Mejia-Cosenza in Queretaro, and Guillermo Villaseñor-Tadeo and Mariana Eguiarte-Morett in Mexico City. The group was significantly strengthened, recently with the parnter-level hire of Luis Antonio González Flores, a former SAT audit-administrator with over 20 years' public sector experience, in February 2019. Villaseñor assisted key longstanding client Repsol in establishing its operations in Mexico in midstream and downstream oil and gas sectors; while León-Santacruz was instructed by private equity fund Investar Capital Partners regarding its $150m restructuring. In other work, Eguiarte Morett assisted the AES Corporation with the structuring of a tax-efficient fund to obtain investments to expand its energy operations. Support comes from senior associates Emilio Garcia and Jorge Lopez. Other clients include Grupo Empresarial Angeles, Schwan Stabilo, GMD Eurocast, H&M Hennes & Mauritz, Libbey, and Clariant.
SMPS Legal houses 'top performing professionals with years of experience, seeking the best approach for clients' needs. The lawyers also possess cross-cultural nous and the ability to communicate and build long-term relationships’. Jorge San Martín and Ana Paula Pardo head the nine-strong practice group, which also includes tax and administrative litigation specialist Christian Solis, with key support coming from associate Mariam Bojalil. The practice also works in conjunction with independent international tax expert and leadng lawyer Manuel Tron when required. Working closely with the firm’s other departments, the team handles a broad array of tax consulting and litigation work including estate planning; acquisitions, mergers, spin-offs and corporate reorganisations; corporate restructuring;and corporate and international taxation in connection with the real estate, private equity and oil-and-gas industries. Other matters include efficient corporate funding structures, repatriation of resources, acquisition and sale of corporate assets; tax refunds and tax incentives; and the representation of clients before Federal Tax Authorities. Recent work highlights included assisting key client Grupo Axo (through its company Aloxom Marketing), with the acquisition of Tennix, which operates brands in the Mexican market; and advising Trade Finance Solution on tax matters relating to structuring and negotiating the terms and conditions for financing Mexican clients. It also advises Gerdau / Sidertul on a regular basis, including -most recently- on a litigation procedure in relation to a wrongfully assessed tax credit; and acted for Lufthansa Systems on the establishment of a representation office in Mexico. Uniquely, the firm has offices in Mexico City, Bogotá, Dallas and Calgary. Other clients include Danone / Bonafonte, Ecom Trading, Phenolaeis, and Gentera.
White & Case S.C. continues to act as Mexican tax counsel to Kansas City Southern in a private ruling case before the SAT related to VAT charged on global transport services that begin outside Mexico and terminate in-country. In other recent work it represented Newmont Mining Corporation in the $10bn acquisition of Goldcorp; and, working with the New York-office, represented CFE (and wholly-owned subsidiaries, CFE Transmision and CFE Capital), on its $879m public global offering of FIBRA E energy-and-infrastructure trust certificates - the first issuance of this type of securities in Mexico's energy sector. The cited highlights reflect the practice group’s orientation towards representing clients in the field of financial services taxation, on projects and mergers and acquisitions, and in high-stakes tax litigation cases, calling on the firm’s international network as necessary. The ‘excellent’ young partner Guillermo Aguayo leads an eight-strong team, other members of which include: Ismael Reyes Retana, Antonio Cárdenas , and associate Andrés Gonzalez-Meyer, all of whom are litigators; and the very active Juan Ignacio López, also an associate. Afirme Grupo Financiero is another client.
Foley Gardere Arena
Foley Gardere Arena works closely with its international offices to advise clients on tax planning, transfer pricing, tax mediation and litigation, along with administrative and constitutional challenges, negotiations to obtain tax incentives, customs regulations and audits. Recent clients have included Faurecia, Herbalife, IGT (previously Gtech Corporation), Whirlpool, Brightstar, Ford Credit, Littelfuse, Peugeot Finance, Tesco, and Worldventures. Both recommended, Roberto Arena and Fernando Camarena co-lead the practice. Arena specialises in treaty structuring, M&A, real estate, corporate restructurings, and litigation; while the ‘exceptional’ Camarena covers M&A, corporate matters and litigation, and has expertise in issues affecting foreign and particularly US corporations, joint ventures, and country-specific treaties on double taxation. Associate Aldo Mendoza (domestic tax litigation and complex international tax litigation) is another name to note.
According to one peer Hogan Lovells ‘entered the market well’. The 12-strong practice has expertise in income tax and double tax conventions (transactional and cross border operations), VAT in exportation of services, and indirect taxes, as well as disputes, social security and wealth management; it advises clients on transactions and before the authorities, and has particular strength in the transportation, food, and services industries. Recent mandates saw the team assist Cardone Industries with its operations in Mexico, including in several audit procedures before the tax authority; represent NYK de México regarding a tax assessment issued by the tax authority; advise Harman Kardon on its corporate structure, income tax matters and various transactions; and counsel Brazilian company SmartFit Escola de Ginástica e Dança on its $73m acquisition of a strategic 51% capital stock holding owned by Grupo Marti. Arturo Tiburcio co-heads the practice with Jaime Espinosa, who divides his time between the capital and Monterrey. The two are supported by senior associates Francisco Palmero and María Teresa Garza in Mexico City and Monterrey, respectively. Other clients include Acciona, Cushman & Wakefield, Conservas La Costeña, Philips Mexico Comercial, Alloys Merchants and Marsh McLennan Companies.
Ortiz Abogados Tributarios S.C.
Tax boutique Ortiz Abogados Tributarios S.C. covers the three pillars of tax legal advice: consultancy, litigation, and representation before the authorities. More specifically, it represents clients in tax credit assessments and resolutions issued by the authorities, in consultations and audits, and it advises on day-to-day, strategic, and operational tax matters. Name partner Gabriel Ortiz is a market reference; he is a former president of the Mexican bar association (2013-15), and is renowned for his litigation skills. He is flanked by Carlos Yáñez Alegría and Carlos Monarrez, who handle litigation, advisory and administrative matters, and litigation and planning, respectively. Also noted is Pablo Ramirez Morales who made partner in January 2019.
PricewaterhouseCoopers, SC is a significant player in the Mexican market with 20 offices the length of the country and a broad offering of diversified tax consultancy and representation. Standout practitioners include managing director Jesus Francisco Morales; José Ricardo Soto, who heads the administrative litigation practice; head of deals Luciano Scandolari; Sandro Castañeda, who has over 25 years’ experience and handles tax consulting in relation to M&A as well as litigation; Monterrey-based José Antonio Garduño also has over 25 years’ experience and handles consulting and litigation as head of the legal tax practice for the northeast of the country; and Carlos Manuel Martinez, who works out of El Paso. Also noted are senior associates Cynthia Angélica Covarrubias (tax litigation and amparo cases), Alberto Diaz de Leon (tax and administrative law), and Juan Manuel Pérez. Past clients include Aeropuertos Mexicanos del Pacífico, Médica Sur, Corporación GEO, The Pepsi Bottling Group México, Alsea, Samsung Mexicana, Tyco Electronics México and Grupo Marítimo Industrial.
Founded in 2013, Rizo, Erreguerena y Garza-Cantú, S.C. is an 'impressive' tax boutique with stalwart practitioners, such as Juan Carlos Rizo who spent over 10 years at the SAT handling litigation and amparo cases, Carlos Garza-Cantú Aguirre who also worked at the tax authority for over a decade undertaking domestic and international tax matters, and ‘solid and experienced’ José Miguel Erreguerena Albaitero who handles consultancy work. Today all three have over 20years' experience and equip the small practice with the ability to handle a full range of consultancy work, representation before the tax authorities, and litigation on tax and administrative matters, including before constitutional courts.
Mariano Calderón, who has over 20 years’ experience, and senior tax counsel Agustín Gutiérrez co-lead the six-strong practice at 'legal services institution' Santamarina y Steta . The pair focus on taxation; tax, constitutional and administrative litigation; foreign trade and AML matters; and general tax and tax analysis of corporate and financial transactions, respectively. The team supports the work of the corporate, transactional and bankruptcy practices on issues concerning state and federal taxes, transfer pricing, representation before the tax authorities and social security matters, with associates Karina Robledo, Stephanie Uribe and Jair Vaca all involved in both contentious and consulting work. Recent matters include advising Abengoa (and subsidiaries) on the Mexican aspects of its global €1.17bn restructuring; and General Motors de México on various tax matters that include advisory on transfer pricing compliance and tax audits, and representation in tax litigation.
Well regarded, Von Wobeser y Sierra, SC’s tax team works closely with the firm’s other departments, handling preventive advice, consulting and litigation. In highlight work the group continued to advise BMW on all tax-related matters concerning its investment in Mexico to build a a new luxury-car factory in San Luis Potosi; assisted Invenergy on the tax implications of subsidiary Parque Eólico de Fenicias development of a 168MW wind parkin the state of Nuevo León; and Burger King Corporation in tax-related matters related to the sale of assets and stock of entities in Mexico as part of its restructuring of operations. Fernando Moreno leads a practice group that includes senior associate Jorge Díaz; both also handle international trade and customs. Other clients include Terrafertil, Faurecia Sistemas Automotrices de México, Creation Investments Capital Management, Takata, PrimeiroPay, Cimentaciones Mexicanas, and German Centre México.
Acedo, Santamarina, S.C
Acedo, Santamarina, S.C is renowned for its ‘technical expertise, quality of advice and being great to work with’; the lawyers are ‘capable, they understand the needs of the customer', and 'always give us updates and an indication of what the next steps are’. The four-strong team handles tax advisory, audits and litigation work, along with social security, administrative law and international trade matters, primarily for clients in the food and drink, clean energies, telecommunications, education and services sectors. The groups recent mandates include advising on the tax implications of selling toys online and on the application of local contributions regulation; on a nullity lawsuit before the Federal Administrative Court challenging tax assessments determined due to alleged non-payments during the 2008 tax year - a case which was successfully resolved for the client; and on the application of a national tax to an international gas pipeline. ‘Incredibly smart’ practice head Rafael Tena Castro is ‘highly recommended for his expertise and savviness’. Other clients include Servicios Eólicos Globales, Fidelity Marketing, Infraestructura Marina del Golfo, Vicrila Glass Manufacturing, and the Mexican subsidiaries of Pepsico Internacional, Top Victory Electronics, Ghenova Ingeniería, PRGX and Mattel .
The tax practice at Creel Abogados, SC is integrated into the firm’s corporate department and therefore focuses primarily on M&A, capital markets, financing, estate planning and corporate reorganisations, along with international trade and litigation. Recent work included advice on joint ventures, real estate acquisitions, finance and corporate restructuring, share sales, fund structuring, issuance of debt backed securities and VAT refunds for clients such as Cummins, Corporación Inmobiliaria Vesta, Kerzner Group, Danone, Xylem, and Belcorp International. Carlos Martínez co-heads the practice with Javier Portas; both have over 15 years’ experience in the area. Other clients include Grupo Medios, Vector Partners, Altum and Edgewell Personal Care México.
Deloitte Legal Mexico
Possibly the smallest of the Big-4, Deloitte Legal Mexico nevertheless has offices in nine cities, offers particular strength in litigation and also covers both the consultancy and advisory side of the practice. Stand out names among the 50 national practitioners include litigators Abel Camacho Brito in Querétaro, Carlos Alberto Ramirez in Monterrey, and Ricardo Santoyo and Hugo Romero in Mexico City; also in the capital, Eduardo Revilla deals with high-end transactional and advisory matters and Jorge Antonio Jimenez handles general corporate taxation, VAT, international taxation, double taxation treaty application, customs law, and tax audits; Laura Rodríguez Berron has extensive experience of the Central American region as well as Mexico and handles tax planning, corporate income tax, VAT, and special taxes on production and services; Eduardo Barron advises on international tax and transfer pricing; and Federico González de la Vega has over 20 years’ experience in corporate tax with a focus on the manufacturing, consumer, construction and technology sectors, and experience handling corporate restructuring, M&A and due diligence; in Guadalajara Raciel Flores Talavera undertakes tax controversy, transfer pricing, and customs and social security matters.
EC Legal Rubio Villegas’s tax consultation and litigation practice handles domestic and international tax in relation to M&A, restructurings, and spin-offs; estate planning and wealth management; tax audits, disputes and planning; risk analysis, convenience and the management of permanent establishments in Mexico; real estate tax planning and tax refunds. The firm was formed by merger in 2017, giving it an interesting and unique national footprint, with offices in Mexico City, Querétaro, Ciudad Juárez, and Irapuato; in March 2019 it expanded further, absorbing Chihuahuan firm BGM Consultores Legales, and subsequently -in July- opening a sixth office in Puebla. The practice is lead by Arturo Bañuelos, and includes Edmundo Hernández in Mexico City, Felipe Mendoza in Querétaro and Fernando Holguín in Ciudad Juárez. Franco Herrera Sánchez joined the Irapuato office as of counsel in January 2019, having previously been Undersecretary for Investment Promotion of the Ministry for Sustainable Economic Development of Guanajuato.
Escalante & Asociados
Escalante & Asociados has ‘a very fast turnaround and great expertise’; the lawyers are ‘always designing excellent strategies’ and ‘get the job done’. The small firm provides advice on anti-corruption and corporate social responsibility, private wealth law and anti-money laundering, in addition to its highly regarded tax and international trade and customs, practice. Covering both contentious and non-contentious matters, the team had an active year assisting clients before the relevant authorities in resolving tax liabilities under the IMMEX programme, General Import and Customs Proceedings Duties, and regarding verification of origin cases, VAT, income tax and in audits. Valued by clients, Ángel Escalante Carpio heads the practice with key support from senior associate Berenice Castañeda. Clients include Química y Farmacia, Agnico Eagle, JSa Arquitectos and the Mexican subsidiaries of Perrigo, Tupperware Brands and Geodis.
The tax practice at Haynes and Boone, SC handles cross-border matters, including corporate and M&A, finance, real estate, and shipping, as well as audits and challenges before the authorities; its caseload evidences a certain focus on the oil-and-gas sector. In highlight work, and working in conjunction with several of its US offices, the team assisted the equity owners of Corporación POK in the sale of stock to Nucor Corporation. Other work saw the Mexico City office advised Blue Marine on the customs and tax implications of acquiring and importing an offshore vessel; and represent FCC Servicios Industriales y Energeticos in the regularisation of certain denials of the tax authorities related to electronic signatures and electronic invoicing through the Mexican Taxpayers Advocate procedure. Recommended practice head Edgar Klee Müdespacher leads a small-but-capable four-strong team that includes associate Mauricio Reynoso. Other clients include NextEra Energy Resources, Newpark Resources, Semgroup, Trive Capital and Tresmontes Luccheti Mexico.
Senior counsel Eugenio Grageda leads the newly-established and relatively small practice at Holland & Knight , having arrived from Turanzas Bravo & Ambrosi in July 2018. Praised by clients and peers alike, he is a ‘state of the art attorney’: ‘always available’, ‘exceptionally intelligent and creative, and very attentive’, with ‘outstanding coordination with his US team’. The practice, which offers ‘good value for money’, benefits from the firm’s international network and advises clients on domestic and international corporate reorganisations, investment vehicles, start-ups and financing structures, as well as on the design of tax-efficient strategies for different types of transactions; expansion into Mexico; and offshore tax compliance. It also undertakes tax audits, legal challenges and before various local, state and federal regulatory and governmental agencies; estate tax and succession planning; and compliance with the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS).
Ortiz, Hernández y Orendain, S.C.
Highly rated by peers, Ortiz, Hernández y Orendain, S.C. is another firm whose tax practice goes hand-in-hand with its international trade and customs expertise; on the fiscal side the practice handles transfer pricing, audits, transactional matters, tax strategy, litigation, social security, tax refunds, and international taxation. Formerly at Basham, Ringe y Correa, S.C., Luis Ortiz-Hidalgo is considered one of the best tax lawyers in the country; he is flanked by his fellow name partners, Gerardo Hernández and Ignacio Orendain, who are institutions in their own right.
Thompson & Knight LLP
With a strong focus in the energy sector but also covering mining, real estate, pharmaceuticals and finance, the ‘available, professional, and reliable’ Thompson & Knight LLP provides advice on tax planning and compliance (primarily within the context of corporate reorganisations), joint ventures, financing, mergers and acquisitions, spin-offs, and inbound and offshore investments; it also handles client representation before the tax authorities in audits, settlements, rulings, and mutual agreement procedures. Recent work includes instruction by an insurance company on a transfer pricing examination focused on cross-border intra-group transactions and a corporate reorganisation; advising a mining company with regard to a corporate reorganisation; and assisting several energy companies with operations in Mexico. Mario Barrera Vázquez leads the practice.