A sizeable group of tax practitioners at Basham, Ringe y Correa, S.C. supports a stellar client base on the full suite of tax planning advice, as well as guiding them through audits by the tax authority and in tax litigation. The practice is one of the best-regarded names in the market for tax controversies, from revocation appeals and nullity actions to customs or constitutional litigation; while on the structuring side the firm covers everything from due diligence and corporate reorganisations, to tax incentives and indirect taxation. Key contacts in the team include: Gerardo Nieto, who has acted in a number of precedent-setting tax litigations; Gil Zenteno, who draws on over 30 years' experience in tax law; tax strategy expert Alejandro Barrera; Sergio Barajas, a specialist across consulting, litigation and strategy in tax, customs, foreign trade and administrative law; Victor Barajas, who frequently represents clients -including Fortune 500 multinationals- before tax authorities in rulings' requests, audits, tax refund claims and settlement procedures; Francisco Matus, whose focus is on the structuring and transactional side of the practice; and head of the foreign trade and customs practice at the firm’s Monterrey office, Roberto Serralde. Among a strong crop of associates, up-and-coming litigator Norberto Ruiz stands out.
Tax in Mexico
Basham, Ringe y Correa, S.C.
Gerardo Nieto; Gil Zenteno; Alejandro Barrera; Sergio Barajas; Víctor Barajas; Francisco Matus; Roberto Serralde
‘The work of the firm’s tax practice is spectacular in designing and offering effective solutions in accordance with the legislation. Compared to other law firms, Basham has the most current information and movements in the matter.’
‘Victor Barajas is exceptional and his work is particularly outstanding due to his knowledge of the market and the criteria of the tax authorities.’
‘Basham’s legal team is highly professionally prepared. They are excellent in tax trials, they have given us excellent results.’
Chevez Ruiz Zamarripa has a comprehensive offering in tax law -long the firm’s core strength- that assists clients with a wide range of tax and legal services, including advice on international transfer pricing and double taxation. The department regularly advises on the tax implications of corporate restructurings, new financial models, spin-offs, M&A and projects. For contentious issues, the firm has practitioners well-versed in audit procedures, as well as alternative dispute resolution and court proceedings against the tax authority. The practice group is spearheaded by the renowned Manuel Sáinz, a senior figure in the Mexican market who has overseen tax matters at the firm since its inception. Another key figure is Ricardo Cervantes, who has over 25 years’ experience representing domestic and foreign clients in administrative and tax litigation. Pablo Corvera and Ramón Orendain are both leading tax litigators; on the advisory side, César Fares has particular experience acting for mining sector clients, and Yoshio Uehara is a key contact for transfer pricing advice. Another experienced figure, transfer pricing and international taxation expert Ricardo Rendón is a notable consultant for transactional matters. One of the department’s up-and-coming partners, Daniel de la Parra had a very active 2022.
Primero Empresa Minera
- Acted for Primero Empresa Minera in a diverse range of transfer pricing audits.
Admired by clients for its ‘excellent technical knowledge and good communication skills’, the tax department at Creel, García-Cuéllar, Aiza y Enríquez, S.C. regularly assists with the tax elements of many of the major transactions in the Mexican market. The department is particularly renowned for its prowess in the capital markets arena where complex tax issues are involved. The firm has an extensive client base across numerous sectors and industries but is especially strong in the private equity space; Blackrock is among those that look to the firm for tax advice. Alejandro Santoyo heads the team and has a strong client base of finance sector clients, and Jorge Correa is another market-leading tax expert with strengths in capital markets and financial products. Omar Zúñiga‘s practice has an emphasis on international tax, advising multinational companies operating in Mexico and Mexican companies with business abroad; while Luis Vázquez is the most senior contact for litigation and other contentious tax matters. Talented younger partner Eduardo Brandt focuses on corporate and international tax in relation to financial, capital markets and M&A transactions; and counsel Luis Salinas supports the tax controversy practice.
‘Creel’s tax practice stands out for the technical capacity of its partners and associates. Faced with a stricter tax environment, companies and their managers require more than lawyers, business advisors. Creel’s interdisciplinary team provides comprehensive advice that offers solutions to highly complex problems, which makes it stand out from the rest of the firms.’
‘The interdisciplinary team that Creel’s tax practice has allows them to provide comprehensive advice. Specifically, the fact of having lawyers, accountants and transfer pricing specialists has proven to be useful in solving problems since these are approached from different points of view, accounting and legal being one of the most relevant.’
‘They construct an excellent relationship with the client that is reflected in the interest in getting to know the business in depth and the real objectives of their projects. We admire the closeness and promptness in addressing concerns, and the quality of the preparation of creative, efficient solutions. and effective.’
‘High level of knowledge on Mexican tax rules and experience with novel arguments. Able to find solutions where other firms were not.’
‘Team of high technical knowledge, practical, with great availability and service to customers. They have a great balance between technical knowledge and the ability to easily execute the proposed solutions.’
‘The tax team has provided excellent service to our clients and it has been extremely easy for us to work with them on important litigation projects. The litigious matters in which our clients and we have had the opportunity to work with the Creel tax team are matters that require professionals with specialization in different branches of law such as administrative, commercial, telecommunications and technology, and the tax team of Creel has come out to collect the opinions and suggestions of all the participants to incorporate them into his writings and promotions within the trials.’
‘We believe that their best qualities are the detailed monitoring of the different stages of the process, the communication to the other participants in litigious matters, as well as their knowledge of precedents both from his firm and from third parties.’
‘Alejandro Santoyo is a benchmark in the Mexican market, the most outstanding lawyer in tax consulting in Mexico. Omar Zúñiga is also highly efficient and is able to explain complex topics in a simple way.’
Apollo Global Management
Canadian Pacific Railway
Canada Pension Plan (CPP)
- Advising Apollo Global Management on its conversion of a debtor-in-possession (DIP) facility into Grupo Aeromexico (AMX), as a result of AMX´s chapter 11 procedures in the US.
- Advised StepStone Group on the structuring of a $102.5m public offering of a securitised portfolio of direct loans via Certificados Bursátiles Fiduciarios on Mexico’s BIVA stock exchange.
- Acted for Citigroup on the tax aspects related to the purchase of the Mexican subsidiary of Deutsche Bank´s licensed entity.
Galicia Abogados S.C. has rapidly established a strong tax practice that makes for an excellent choice in the most complex tax-heavy transactional matters, and is increasingly seen as a destination for pure tax instructions. The practice has recently been particularly active in the financial sector, supporting financial institutions in the face of a more aggressive position on the part of the tax authority. The firm continues to invest in the practice, hiring Eduardo Michán from Deloitte Impuestos y Servicios Legales, S.C. in mid-2022, and also bringing in senior associates Eduardo Espinosa and Ivonne Montaño from Creel, García-Cuéllar, Aiza y Enríquez, S.C.; all three bolster the tax offering to clients in the private equity space. Michán joins a group of five practice heads, coordinating the team alongside Gabriela Pellón and Federico Scheffler, who focus on tax consultancy; and Edson Uribe and Denise Lester, who are the contacts to note for tax disputes. At associate level, Alejandra Paniagua and Sebastián Ayza are both gaining profile on the tax consultancy side, while as regards contentious matters, Fernando Gómez and Alejandro Madero are the names to note.
Gabriela Pellon; Federico Scheffler; Eduardo Michán; Edson Uribe; Denise Lester
‘Very up to date knowledge of tax aspects involving VC transactions and foreign investment, and cross-border debt facilities.’
‘Federico Scheffler and Sebastián Ayza are extremely diligent and quick with providing advisory. Very good business-knowledge and understanding that facilitates negotiations in the fintech environment.’
‘Galicia is an excellent law firm. They have supported in tax and contractual matters with the best quality. Its internal teams are excellent professionals.’
‘Eduardo Michán is an excellent professional. Always available; he has impeccable detail and customer service. His advice is very accurate, he transmits a lot of security in the most complex issues and he connects very well with the client and their needs. I would recommend him without hesitation.’
Banco Nacional de México
Samsung – SNB Technologies
Institución de Banca Múltiple
Grupo Financiero HSBC
Sony Pictures Distribution Mexico
Sony Pictures Home Entertainment de México
Tata Consultancy Services México
Inter-American Development Bank
KPS Capital Partners
Inmobiliaria Monte Athos
Productores de Vinagre Provisa
Fundación Espacio V
Lomelin Administracion de Proyectos
Servicios Administrativos Aluminicaste
Grupo Constructor Legacy
Hoteles City Express
Evertec México Servicios de Procesamiento
Bank of America – Administradora Mel
Promotora Inmobiliaria Masalto
IKE Grupo Empresarial
Grupo Nacional Provincial
García Tagliavini Producciones
Vector Casa de Bolsa
- Advised Hoteles City Express and its operating affiliate Operadora, on the tax aspects of entering into a strategic relationship with Marriott International, and the sale of five brands.
- Assisted Banco Nacional de Mexico with tax, regulatory and labour issues of the implementation of a complex restructure in the context relating to the Mexican Labour Subcontracting Reform.
- Assisted UDRA, as part of a multi-practice team, with the Mexican Labour Subcontracting Reform.
Baker McKenzie Abogados, S.C.
The tax team at Baker McKenzie Abogados, S.C. is appreciated by clients for its ‘very pragmatic approach’ and is especially well-versed in cross-border matters, drawing on the firm’s international network. The practice has a particular focus on the oil-and-gas, automotive, manufacturing and finance sectors. As of March 2023, coordination of the department is the responsibility of Jorge Narváez-Hasfura, who has over 35 years’ experience acting for companies in tax disputes, and advising as regards international taxation and transfer pricing matters; he is widely recognised as a leader in the tax law market. Previous practice head Luis Adrián Jiménez Robles remains an integral part of the group and focuses on Mexican inbound restructuring planning for multinationals and multijurisdictional groups headquartered in North American and Europe. International tax and private wealth are pillars of Javier Ordoñez’s practice; and Juan Carlos Valles is an experienced name in complex tax and customs litigation. Diana Juarez is another name to note for international taxation and tax planning, while at senior associate level, Graco Sáenz stands out.
Luis Adrián Jiménez Robles
‘They have a very pragmatic approach and look at things with the intention of finding a solution. They do not repeat the clients the problem to be faced but how to solve it. They have one of the strongest teams in the region. The fact that Baker has offices all over the globe makes them a one-stop shop. This is valuable nowadays, when the flow of information is critical and when having too many people involved in a project can affect the final outcome.’
‘Javier Ordoñez is a super knowledgeable lawyer. He knows the law and regulations inside-and-out. His charismatic approach and easy access made him a very reliable person for us. Clients and the industry in general speak very high about him. He is a hard working person and someone who rolls up his sleeves when needed.’
‘The systematic and clear application of the regulations. Always maintaining a good balance between different roles.’
- Assisted a client with the tax implications resulting from a rejection by the tax authority of the tax deduction on expired medications, as well as with the new compliance issues.
The tax practice at Mijares, Angoitia, Cortés y Fuentes S.C. ‘integrates different specialties’ across both advisory and litigious aspects, providing a robust foundation on all tax aspects of the major transactions that the wider firm advises on. Along with such high-end transactional support, the team also acts for multinationals in tax audits and litigation, as well as providing day-to-day counsel on effective tax structuring. Enrique Ramírez is a tax specialist with a focus on consulting, controversy and litigation; he has experience acting for the biggest names operating in Mexico and his recent mandates includes matters in the automotive, finance and communications sectors. Ramíez co-leads the department alongside Nora Morales, who is the name to note for transfer pricing and international operations; day-to-day tax planning advisor Manuel Tamez; and Luis Monroy, who assists with the tax elements of financings, M&A and capital markets deals. July 2023 saw Armando Elsharkawy raised to the partnership; he demonstrates notable strength in tax advice on real estate and infrastructure deals. The practice also has a strong pool of associates with Carlos Jiménez Chao, Eduardo Orellana and Swad Abbud all experienced figures.
Manuel Tamez; Nora Morales Rodríguez; Enrique Ramírez Figueroa; Luis Monroy
‘As an office, it is one of those that are currently providing services and attention to clients according to how the fiscal practice is moving, considering the changes in the government, trained people, willing, with an attitude of help and support.’
‘Ability, knowledge, service attitude.’
‘Great team of professionals, they integrate different specialties and are deeply involved in the issues.’
‘Extensive knowledge and experience of the subjects.’
- Represented Grupo Televisa in the merger of its media, content and production assets with Univision.
- Advised SoftBank Latin America Fund on the tax structuring for its investment of MXN$1,500m in exchange for an indirect interest of 7.5% of the capital stock of certain subsidiaries of Corporativo GBM.
Since establishing its tax practice in 2017, Ritch, Mueller y Nicolau, S.C. has rapidly grown its offering in the area, and -more recently- has seen a rise in its client base for contentious tax work. Its advice on the latter front encompasses the implementation of preventive measures, negotiations with tax authorities as audits are begun, mediation procedures, and litigation procedures, including before the Supreme Court. On the transactional side, the practice has a strong standing in the real estate sector, advises various parties on major M&A, while in capital markets, the tax team counsels the firm's strong base of banks and financial institutions. Oscar López Velarde has represented multinationals on the gamut of contentious procedures, including administrative appeals, mediation, annulment trials and amparo lawsuits. Santiago Llano Zapatero has broad sector experience but is especially familiar with the tax landscape of Mexico’s energy sector. Juan José Paullada Eguiaro concentrates on tax controversy and litigation; all three above mentioned lawyers jointly lead the practice group. Senior tax associate Eric Humberto Palacios is a further name to note but former fellow senior Eduardo García Ruiz left in February 2023 to join VCG Partners.
Oscar Lopez Velarde; Santiago Llano; Juan José Paullada
‘They are excellent.’
‘We recommend Oscar Lopez Velarde.’
‘I’d highlight the technical and practical knowledge of the firm’s lawyers on this subject; they know and understand the client’s needs.’
Wind Point Partners
Grupo Salud Auna México
Ainda – Energía & Infraestructura
Bank of America Securities
- Assisted Wind Point Partners with the structuring of its acquisition of Palmex.
- Represented Ainda in the acquisition by farm-in transaction of 8% of the participating interest in offshore oil Block 1.2, contract area 2, owned by Hokchi Energy and E&P Hidrocarburos y Servicios.
- Advised BHP on the merging of its oil and gas portfolio with Woodside Energy.
Drawing on the international know-how and insight into the Mexican tax regime derived from its members’ experience at global law and accounting firms and the Mexican tax administration, the tax department at Sánchez Devanny is adept in audits and litigation, as well as the provision of relevant support on cross-border transactions involving tax treaty interpretation, transfer pricing and foreign tax credit matters. Senior partner Ricardo León Santacruz focuses on Mexican inbound and outbound tax planning and transfer pricing. Santacruz is one of the group’s five practice heads, alongside Guillermo Villaseñor Tadeo, who in his time at the firm has spearheaded the contentious side of the practice; Querétaro office-head Abel Mejía, an expert in advising HNWIs, foreign multinationals and Mexican financial and corporate institutions; Mexico City office-head Mariana Eguiarte-Morett, who, alongside a broad transactional offering, has also developed a niche practice in consumption taxes; and Luis Antonio González, whose main focus is on Mexican MNE’s outbound work and foreign multinationals’ inbound matters, particularly those that refer to related party transactions and international taxation. Pedro Miranda in Querétaro is a further key figure, while at the senior associate level, Emilio Garcia and Jorge Lopez are the names to note.
Ricardo León-Santacruz; Guillermo Villaseñor; Abel Mejía-Cosenza; Mariana Eguiarte Morett; Luis Antonio Gonzalez
‘Networking and timely knowledge that is essential for correct tax advice.’
‘The best attitude and friendliness to explain tax issues with different people, regardless of level or area. We recommend Luis González, Guillermo Villaseñor and Emilio García.’
‘They work from the outset as a team, both with the firm’s own lawyers, and in coordination and integration with the client, always interpreting the sensitivity of each issue.’
‘Very professional and with a great ability to perceive the different sensitivities of the client’s problems and people.’
Nissan Renault Finance
Westpak Avocado Inc
Howden Buffalo Forge
Vitol Marketing Mexico
H&M hennes & mauritz
EQ Capital Partners
Técnicas Marítimas Avanzadas
Grupo Empresarial Angeles
- Assisting Nissan Renault Finance Mexico with an investigation by the tax authority.
- Advising Atento México Holdco on payroll withholding discrepancies.
- Representing Fortinet Mexico in an administrative appeal submitted before the Mexican tax authority regarding a denied VAT refund.
Turanzas, Bravo & Ambrosi
Turanzas, Bravo & Ambrosi is one of the standout tax law boutiques in Mexico and is a strong choice for tax consulting and litigation services, including foreign trade, in addition to accounting, payroll and tax compliance services. Contacts to note in the sizeable team include: Pedro Ramírez, who is strong in tax advice to financial institutions; Mauricio Bravo, a seasoned counsel in tax controversy, estate planning, energy, and international taxation matters; and transfer pricing expert Mauricio Ambrosi. For tax litigation, Jorge Fuentes and Carl Koller are the key names.
Arias y Meurinne, SC
Arias y Meurinne, SC has a robust offering in both tax litigation and advisory matters, standing out in the telecoms sector in particular. A seasoned Mexican tax law practitioner, Pedro Arias is a key contact for both international and domestic tax law matters in the telecoms area. Fellow name partner Luis Eduardo Meurinne also handles both domestic and international tax matters, particularly with regard to investment projects and start-ups; while Pamela Orozco's practice has a notable focus on tax litigation. Leobardo Brizuela is a younger partner that is noted for his tax advisory practice.
Garrigues stands out for its prowess and experience in tax controversies, and has recently gone from strength-to-strength in transfer-pricing advice. The firm’s international presence makes it a strong choice for cross-border matters, particularly those emanating from Spain, and its client base of international companies often instruct the team on corporate tax matters too. Manuel Llaca leads the department and has more than 25 years' experience across tax litigation, transfer pricing and federal tax disputes. Counsel Francisco Barajas is a specialist in domestic tax matters and in resolving issues before the tax authorities; his practice encompasses consulting and controversies. Principal associate Ricardo Fernández de Arellano is especially strong in cross-border work involving Mexico, Spain and the US; and senior associate Iñigo García is the main support on transfer pricing matters.
‘The Garrigues México team is excellent. Their advice is of great technical quality and they always respond quickly and executively.’
‘I would like to highlight the role of Ricardo Fernádez Arellano. His differential point is that having worked at Garrigues Spain he better understands the needs of the Spanish client, adapting better to the times and work typology of this market.’
BMW de México
- Representing CIRSA in several lawsuits against various district and administrative courts over a state duty applicable to gambling companies.
- Advising Sacyr on article 69-B of the federal tax code, which relates to the presumption of simulated operations supported by invoices.
- Advised BMW de Chile on filing a letter ruling request before the local Ministry of Finance, asking for clarification on a legal loophole in a tax reform to the federal fiscal code of Mexico City, regarding tax on vehicle ownership or use of vehicles.
Jáuregui y Del Valle, S.C. is best known in the tax arena for its advice on contentious matters, representing national and foreign clients in trials against federal, local or municipal tax and administrative authorities. Its services also include challenges against credit refusals, tax credit settlements, the imposition of administrative penalties, and undue charges. On the consulting side, the team advises clients on tax planning and consulting, and transfer pricing, as well as providing general assistance on transactional matters. Three lawyers coordinate the department: Luis Gerardo del Valle, managing partner of the firm, who is a reputed figure in the market and has counselled on significant tax transactions in the country; Luis Carballo, who has considerable tax disputes experience; and David Hurtado Badiola, a tax partner with complimentary experience in international trade, economic competition and administrative law. Associate Josemaría Férez Gil is a name to note for tax and administrative litigation, and both Oscar Paz and Asia Leaños are further associate-level contacts to note. Tax consultancy and planning expert Eduardo Medina Zapata departed in December 2022.
Luis Gerardo del Valle; Luis Carballo; David Hurtado Badiola
‘Luis Gerardo del Valle and José María Ferez – they are the ones I deal with the most, but in reality they have a magnificent team, I have been with them for many years, they have my complete trust.’
Amride de México
Corporativo Comercializadora del Bajío
Glenda Estela Hecksher Ramsden
Sistema Educativo Copan
Fibra Terrafina Trust F/2717
El Santuario Resort & Spa
PLA Residential Fund IV Yellow
PLA Residential Fund III Red
PGIM Real Estate MVP Administradora /Fideicomiso Fondo Privado CIB/3849 (PruMex V)
Walton Street México CKD Managers III. (Walton Fund III)
Comisión Federal de Electricidad (CFE)
Corporate Properties of the Americas/CPA Servicios
Operadora de Infraestructura Especializada de Guanajuato (Blackrock)
Finsa Real Estate Management III (Finsa Fund III)
Sura Investment Management
Vinos La Naval
- Advised Fibra Terrafina Trust F/2717 on an agreement that a company would contribute three industrial buildings to Trust F/2717 in exchange for a payment of 50% of the value of each property and 50% of the trust rights in the trust represented by the property.
- Assisted PruMex V with the structuring of a private equity fund that hosts the investment of various publicity traded trusts known as CKDs/CERPIs.
- Advised Walton Fund III on its acquisition of a large portfolio known as Platinum valued at MXN$3,750m.
Nader, Hayaux y Goebel, SC’s tax practice is well-versed in handling all relevant aspects of transactional matters, and is increasingly sought out as counsel for day-to-day tax matters and audits. Clients of the department include institutional investors and both international and domestic companies operating in a variety of industries in Mexico. Adalberto Valadez oversees the practice group, drawing on more than two decades’ experience assisting public entities and private companies with the federal tax implications of their operations; he focuses primarily on federal income tax and international tax. Ana Paula Pardo is the key contact for audits but also acts in estate management and transfer pricing matters; she is supported on all audits by associate Monserrat Reséndiz, who joined from ZG Manuel Tron Consultores in April 2022. The associate pool was further expanded with the addition of Juan Ignacio López from White & Case S.C. in November 2022, joining Iliana García in assisting with the full slate of transactional tax matters.
‘The tax team led by Ana Paula Pardo provides an excellent service; we have had in various cases with the tax authority and almost all of them have gone well, the team always seeking to verify compliance with the tax authority. It is a very personalized and punctual service that she gives as a partner of the law firm.’
‘The people of this tax area are very professional and experts in the matter, there is a team of professional lawyers and a very good service attitude. Ana Paula Pardo is an excellent lawyer who knows how to understand and analyse the problem to find the best solution based on her tax and legal knowledge.’
‘They are always very close to the client, they understand their needs, they are empathetic and they propose solutions that are suitable for the client. They’re committed to satisfying the needs and demands of the client.’
‘Professionals who are always well versed in the issues, it is clear that they have studied it in depth, and they propose practical solutions in accordance with the client, prioritising legal certainty.’
‘Very strong and competent team, we were very happy with their work. Good response times, commercially astute in their legal advice.’
‘We recommend Ana Paula Pardo.’
Macquarie Infrastructure and Real Assets
Ad-hoc Group of Aeromexico Noteholders
- Advising Macquarie Asset Management on the bidding process to acquire Reden Holding, requiring due diligence relevant to the energy sector.
- Assisting Vinci Airports with the acquisition of 29.9% ownership interest of Fintech Advisory in OMA (Grupo Aeroportuario Centro Norte), and the post-acquisition restructuring and continuance of the group.
- Advised BSabCapital as lender and collateral agent on the secured financing to Balear Inmobiliaria, to pay a part of the acquisition of the “Now Emerald Cancun” Hotel located in Cancún, Quintana Roo.
A strong base of Mexican companies and family offices look to SMPS Legal for the full suite of tax advice, from litigation to transactions. For tax consulting, Jorge San Martín is the name to note; his practice encompasses tax and business planning - including M&A, as well as corporate reorganisations focusing on permanent establishments and other tax-related cross-border matters. On the litigation side, Luis Curiel Piña is the lead partner; his workload includes requests for tax credit refunds and undue payments, appeals for revocation, and audits before the tax authorities, among other matters. Francisco Carbajal rounds out the trio of practice heads and his burgeoning practice covers both advisory and contentious matters. In December 2022 the team was bolstered further with the return of senior associate Leonardo González from Grant Thornton UK LLP.
Jorge San Martín; Luis Curiel Piña; Francisco Carbajal
‘Jorge San Martin is a very complete and detailed lawyer, which makes his practice timely and very precise results. Luis Curiel complements the practice with very high level litigation.’
‘What makes this firm unique is that they always try to understand what we need as clients and offer the best solution for us, not try to sell more services unnecessarily. In addition, they offer a lot of availability to explain possible scenarios.’
Codeli / Lavartex
- Assisted Grupo Axo with the tax aspects of its acquisition of Komax Chile and its subsidiaries in Peru and Uruguay.
- Advised Sanfer Farma on its acquisition of a majority stake in Probiomed, a Mexican company that manufactures pharmaceutical products of biotechnological origin
- Acted for Kio Networks on the tax aspects of its indirect acquisition of the minority stake in Mexican company Más Negocio, becoming the target’s sole owner.
Acedo, Santamarina, S.C
For Acedo, Santamarina, S.C’s tax department, the automobile, clean energy, food and drink, industrial engineering, real estate, and telecoms sectors are the source of a significant proportion of its mandates and focus, with major domestic companies in all these areas looking to the team for assistance with both contentious and non-contentious matters. Practice head Rafael Tena Castro is the main contact, supported at the associate level by Luis Shahid Kanchi.
Rafael Tena Castro
‘The treatment that they offer to their clients is personalised, they take great care of the times and the forms.’
‘Rafael Tena shows deep knowledge of the subject and invites dialogue in order to reach useful agreements. He coordinates his work team very well, his example guides the actions of his collaborators.’
Leggett & Platt Automotive Group de México
Garay Componentes Tubulares
Empacadora Campo Frío
Inteligencia en Servicios de Salud
Los Reyes Industrial
Corporación de Servicios XXI
Legget & Platt Group
Rendimientos y Productos Inmobiliarios
- Assisted Leggett & Platt Automotive Group de México with preparing and filing an administrative appeal against the tax assessments issued by the SAT.
- Advised Garay Componentes Tubulares on its administrative appeal before the SAT and a nullity lawsuit challenging a resolution issued by the tax authority refusing to refund MXN$566,525.
- Advised Empacadora Campo Frío on the tax treatment of payments it made to non-Mexican resident companies.
Calvo Nicolau y Marquez Cristerna-DFK, S.C.
The experienced tax experts at Calvo Nicolau y Marquez Cristerna-DFK, S.C. cover the full range of advice in the field, from consulting and strategic planning, to litigation, submission of paperwork to the authorities, transfer pricing and international tax. Founding partners Enrique Calvo and Óscar Márquez have over 75 years of experience between them, and Layda Cárcamo is the other partner-level contact to note.
The tax controversy department at Deloitte Impuestos y Servicios Legales, S.C. is frequently engaged in dealings with the Mexican tax authority on behalf of multinationals’ subsidiaries in Mexico. Well-versed in audits, refunds, negotiations and litigation, the practice has a particular specialism in mutual agreement procedures and arbitration, relating to double taxation treaties throughout the Latin America region. Hugo Romero Cervantes leads the practice and is experienced in representing clients at the Supreme Court. Other key contacts include Carlos Ramírez Larsen in Monterrey, and Abel Camacho Brito in Querétaro.
Hugo Romero Cervantes
Hogan Lovells is a strong choice of counsel for tax audits in Mexico, where it has deep experience representing a diverse range of international businesses. The team also supports the firm’s corporate and M&A practice on the tax aspects of transactions in the country. Leadership is divided between three lawyers: deeply experienced veteran Arturo Tiburcio, who focuses his practice on tax consultation, income tax audits, VAT, and international tax issues, including double tax treaties and transfer pricing; Jaime Espinosa, a Monterrey-based expert on transactional tax law; and counsel Francisco Palmero, whose experience covers the breadth of the firm’s tax offering. Senior associate David Esquivel is another notable contact in the team.
Arturo Tiburcio; Jaime Espinosa; Francisco Palmero
‘The group of tax lawyers is deeply experienced. They are widely recognised in tax practice in Mexico and also undertake operations in other countries, which provides confidence to international companies. It is certainly on par with other high-level firms.’
‘Arturo Tiburcio’s experience in practice is very notable. The customer service of Francisco Palmero and David Esquivel also notable.’
‘Excellent service and knowledge – they are above the average!’
Hyundai Motors de México
Acciona Energía Servicios México
Ocean Network Express Shipment
Grupo Aeroportuario Centro Norte (OMA)
GM Financial Mexico
- Advised Hyundai Motors de Mexico on a transfer pricing audit on its income tax and VAT for the fiscal year 2015.
- Assisted Acciona Energía Servicios México with an audit regarding income and VAT related with the construction of energy plants.
- Assisted QLIKTech México with an income tax audit arguing that it was not proven to have carried out activities with its related parties and clients during the 2014 fiscal year.
As a cog in the firm’s international network of offices, the tax team at Holland & Knight LLP assists multinationals operating in Mexico with both domestic and international tax services. The practice also has tax-controversy capability that is experienced in supporting clients through audits by the Mexican tax authority. Co-leader of the practice Eugenio Grageda receives considerable praise from clients who highlight that ‘his practice is very strong in international issues’. Fellow practice co-head Mario Barrera has experience in both tax advisory and contentious matters. The team was strengthened in April 2023 when - as part of the firm’s hire of a sizeable group to its Monterrey office - tax consultancy and litigation expert Jose Ricardo Ibarra Córdova joined from Sánchez Devanny. Key associate support comes from Catalina Mandujano and Miguel Rosas.
Eugenio Grageda; Mario Barrera
‘I work with Eugenio Grageda. His practice is very strong in international issues. I don’t know of another lawyer with the ease of structuring funds and transactions in other countries like he does. The firm has many contacts.’
‘Eugenio Grageda has a lot of experience in the operation of tax structures abroad and its consequences for Mexicans. He has a great capacity to produce attractive schemes for investors. The best lawyer in international issues with whom I have worked.’
‘Good service and flexible prices. Eugenio Grageda has a lot of practical knowledge.’
‘It is very pleasant to work with Eugenio Grageda. Great expert and friendly as a person. Makes complicated topics easy.’
‘H&K and especially Eugenio, are lawyers of the new generation, who have been disruptive with the old practices of large law firms. They are always available to the client, seeking to have clear communication, without unnecessary formalities and always trying to find practical and efficient solutions for the client, even if this implies lower billing for them.’
‘Eugenio has extensive knowledge of the subject and the sector, both locally and internationally. His experience is of great help and is always a plus that we highly value. He is a person with an extraordinary capacity for synthesis, which makes working with him very easy, especially for people unrelated to legal issues. His priority, above anything else, is always the client. He is available all the time, focused on resolving business doubts and helping us to jump over any obstacle or to avoid encountering one in the future.’
Real Estate Company
Infrastructure Multinational Group
Parques Logísticos del Centro (Global Asset Manager)
FMC Technologies de Mexico
Exeter Property Group
- Advised LNG PTE on establishing a gas plant to process gas in Mexico and distribute it in the United States in a tax-efficient matter.
- Advised a retail company on whether import, storage and delivery services of products by a supplier constitutes a permanent establishment for the supplier for the purposes of the Mexican income tax law.
- Advised a group of supplier companies in the land transportation sector on the tax effect of an international restructure involving Mexico and US companies.
Santamarina y Steta fields a tax litigation department that has recent experience in challenging local environmental taxes, amendments to federal VAT credit provisions, advertising expenses, and real estate tax credits. The practice’s client base has a broad sector coverage and General Motors stands out recently as a multinational instructing the team on the gamut of its tax issues. The department is led by Mariano Calderón, an experienced advisor, particularly as regards amparo, administrative and contentious judicial proceedings. Counsel Karina Robledo focuses her practice on tax advisory matters (as well as money laundering), and associate Jair Vaca supports on the majority of matters.
‘Speed and efficiency.’
‘Individual, specialised, detail-oriented attention and concern for customer satisfaction.’
Controladora General Motors
- Advised General Motors de México on transfer pricing trials.
- Advising Controladora General Motors on tax litigation against a tax assessment of its corporate income tax for the total amount of MXN$1.1bn, regarding the deduction of losses in the sale of certain corporate shares during the 2008 world crisis.
- Assisted Durakón Mexicana with filing a nullity claim against a tax audit order.
White & Case S.C. supports its strong corporate offering on international transactions with a tax practice that assists with all related issues in substantial M&A. The team also acts on contentious tax matters against the Mexican authorities. The practice is led by Elizabeth González, whose main expertise is in corporate income tax and international tax treaties. November 2022 saw the firm bolster the team further at partner level with the hire of Carlos Martínez from Creel Abogados, SC: he brings additional experience in international taxation, transfer pricing and tax litigation to the practice The group can also call on Ismael Reyes Retana in relation to public sector matters.
Carlos Martínez; Elizabeth González
‘White & Case Mexico has lots of tax specialists and is very strong in tax issues.’
‘Elizabeth Gonzalez is an experienced tax lawyer who is very familiar with the Tax Authority’s practice.’
Kansas City Southern Mexico (KCS)
- Advising KCS on the tax aspects of its merger with Canadian Pacific Railway.
In October 2023, the former Escalante & Asociados announced its merger into CMS Woodhouse Lorente Ludlow as the latter continues to broaden its service offering as part of the growth of the international player's regional platform. While it remains to be seen how the combination fares, the new department certainly has proven capability as a stand alone practice. A deeply knowledgeable tax all-rounder, department head Ángel Escalante is characterised as 'being a partner who is particularly attentive to his clients, providing concrete and efficient solutions in short periods of time'. The practice assists with a broad range of tax issues (including capability in the international trade area), with contentious tax matters a particular forte - Escalante can draw on lengthy tax litigation experience, as well as handling audits and mutual agreement procedures. In an advisory capacity, the team excels in the real estate sector, double taxation, digital services, project finance and capital markets related tax matters. Associates Angélica Cacheaux and Gabriel Rojas provide key support. However, Jorge Díaz Carvajal - who had arrived as a partner in June 2022 from Von Wobeser y Sierra, SC, chose to exit with the merger and has established his own practice.
Ángel Escalante; Jorge Díaz
‘They have developed a series of technological tools that have increased the efficiency, precision and speed of legal advice.’
‘The firm is made up of a team that meticulously studies every detail of the issues and the law that applies to them, offering sophisticated solutions at the exact moment and having an integrated vision of law, economics, business and technology.’
‘A firm that stands out for being constantly updated on the latest issues in the practice of the profession, likewise, they keep their clients informed so that they have due compliance with the norm. Your customer service has a human factor that allows you to generate a close relationship.’
‘Ángel Escalante is characterised by being a partner that is particularly attentive to its clients, providing concrete and efficient solutions in short periods of time. Angélica Cacheux is an associate with a high degree of knowledge and specialization in her field, so each document she produces is of the highest quality. Gabriel Rojas is an associate with exceptional theoretical and practical knowledge, which is why his negotiation skills are agile and precise.’
‘It is a very specific practice. Being that tax law is very complex to understand, they manage to synthesize it so that the client can understand what the problem is, the possible solutions and realistic terms. The attention is always personalized, the progress of the issues is communicated as soon as possible and with a clear input.’
‘It is definitely a boutique office. They have extensive knowledge of the implications and consequences of implementing each strategy. They are available and always meet their terms.’
‘It is a specialised boutique office. Angel Escalante is truly technical and far exceeds his peers in other firms. Their team has been strengthened and they have many capabilities. I think we’ll soon be seeing them on the biggest issues in the country.’
‘Ángel Escalante is one of a kind. It has a technical capacity superior to its peers. I consider him to be substantially superior in technical capacity.’
Peninsula Investments Group
Grupo Bursátil Mexicano (GBM)
Alloy Merchant Partners
Walmart de México
Orbia Advance Corporatio
Banco Credit Suisse México
Altius México Desarrolladora
Instituto Tecnológico Roosevelt
W K Kellogg Foundation
Combe de Mexico
- Assisted developer Peninsula Investment Group with structuring an efficient international tax framework for its 3rd and 4th private equity funds.
- Advised the real estate leasing platform Casai on the analysis and implementation of its tax structure in Mexico, including cross-border aspects in the United States and Brazil.
- Advised GBM Infraestructura on all aspects of its tax structuring.
DLA Piper Mexico’s revamped tax offering is gaining a foothold in the market since the hire of Guillermo Aguayo from White & Case S.C. in January 2022. He brings experience in complex tax matters relating to cross-border and domestic M&A and corporate reorganisations to a firm whose international footprint draws a high-profile multinational client base. While best known for its non-contentious offering, the team is also gaining profile with regard to tax investigations. Associate Ricardo Mendoza supports Aguayo on the full range of matters; lawyer and accountant Fernando Velázquez is an additional associate contact.
ALD / Societé Generale
Vorwerk & Co
Instituto Anglo Mexicano de Cultura
- Acting for ALD / Societé Generale in its proposed acquisition of LeasePlan.
- Advised Banorte on the tax aspects of an agreement for a strategic commercial alliance with TuHabi.
- Advised Vorwerk & Co. on the tax aspects of the $255 million sale of Jafra’s US and Mexico operations to Betterware.
Boutique firm Kavanagh Gorozpe has ‘highly specialised and experienced lawyers in the tax field’, and assists clients with tax consultation and planning, including estate planning and investment structuring, domestic and international taxation, representation before the tax authorities, and litigation. Practice head Paul Kavanagh is valued for his ‘quality and depth of work’; while key associate Ana Karen Aguiñaga, in addition to being a tax litigator, has experience in advisory matters for domestic and international companies. Former practice co-head Luis Ignacio Martel departed the firm in December 2022.
‘What distinguishes the firm is its commitment to the quality and depth of its work, delivery times and attention (including partners).’
‘Paul Kavanagh – Quality and depth of work, value for money, timely delivery, personalised attention.’
‘Kavanagh Gorozpe is a leading firm in its practice, and its team is made up of highly specialized and experienced lawyers in the tax field. The team also includes members who have a background in corporate law, enabling them to provide integrated and customized tax solutions to meet the needs of their clients.’
‘Kavanagh Gorozpe has a focus on technology and innovation, so his advice in the telecommunications industry enabled Paul Kavanagh to provide a first class service.’
- Advised Etam on the negotiation and structuring, from a tax perspective, of a joint venture with Diltex.
Ortiz Abogados Tributarios S.C.
Specialist tax firm Ortiz Abogados Tributarios S.C. has operated in the Mexican tax law market for 25 years and is particularly well-regarded for its litigious capabilities. Senior partner Gabriel Ortiz is a reference in the country for tax controversy matters, and both Carlos Yáñez Alegría and Carlos Monarrez are reliable advisors on the advisory and contentious fronts. Associate Paulina Edith Castillo provides robust support, especially as regards constitutional matters.
Parás Asesores Fiscales, S.C.
Tax law boutique Parás Asesores Fiscales, S.C. is valued for its ‘high specialisation in tax’ but also at a more focused level for its practitioners’ ‘extensive experience in the banking and insurance business’. The firm is well-versed in advising companies operating in Mexico on efficient commercial tax structuring, along with support relating to transactions, particularly in the capital markets arena. On the contentious side, tax litigation and support on audits are both regular sources of instruction for the team. The key contacts to note include senior tax controversy figure Jorge Covarrubias; Mariana Covarrubias, who has experience advising on multijurisdictional tax disputes; and Alejandro Guízar, who acts across both consultancy and litigation.
‘The Parás law firm has a highly trained technical staff that is very well focused on the needs of its clients. Compared to other law firms, Parás has a more personalized service and greater attention to detail.’
‘Parás differs from other firms due to its high specialization in tax, which makes them experts in the field.’
‘Among other areas or business segments that they serve, Parás Asesores Fiscales serves the financial sector with extensive experience in the banking and insurance business. Not all firms have specialization in the financial sector, which adds value to the services provided by Parás Asesores Fiscales.’
The tax team at Von Wobeser y Sierra, SC is best known for its strength in double taxation and for assisting clients with beneficial tax structures for foreign and domestic companies. The practice also supports the firm’s corporate team and often advises on the tax aspects of business restructurings and M&A transactions. In January 2023, the firm absorbed Alejandro Torres & Asociados, which added two lawyers who now oversee the tax department in conjunction with of counsel Fernando Moreno: Alejandro Torres, an experienced tax specialist who has acted in numerous complex tax disputes before the Mexican courts; and counsel Luis Enrique Torres whose practice is focused on the resolution of tax and administrative disputes. Associate Juan Manuel Moran was also part of the incorporation and provides strong support, particularly as regards tax audits.
Alejandro Torres; Luis Enrique Torres; Fernando Moreno
‘We appreciate the follow-up and alternatives proposed to clients. They are always available to attend to issues that arise from simple to complex questions.’
‘I always manage to contact them and they give an immediate response, creating a long-term relationship of trust.’
- Representing ArcelorMittal against tax assessments for various fiscal years amounting to over MXN$2bn.
- Assisting Casas Javer with a tax assessment issued by the tax authority amounting to MXN$300m.
- Acting for a subsidiary of Grupo Aeromexico regarding a tax assessment issued by the tax authority for MXN$180m.