Tax in Mexico
Chévez, Ruiz, Zamarripa y Cía SC
Market authority, Chévez, Ruiz, Zamarripa y Cía SC, has a first-class tax department, which houses a large team of lawyers and accountants with an impressive ability to handle tax litigation and tax consulting matters. The practice includes experienced and skilled litigators such as the outstanding Manuel Sáinz, who heads the area; Ricardo Cervantes and Alejandro Torres, who has particular expertise in alternative dispute resolution (ADR) proceedings in tax issues; and César De la Parra and Daniel De la Parra, who lead the anti-money laundering practice. On the consultancy front, the firm includes notable transfer pricing specialist Ricardo Rendon; César Fares, who has a focus on audits, especially for clients from the mining sector; Carlos Naime, who covers banking and finance tax; and Pablo Corvera, who is especially known for handling financial matters. Rodrigo Farias and Gibran Hazar were promoted to partner in January 2020.
‘They have extensive experience, multifunctional teams that help them generate new ideas, their customer service is very good because they try to make it personalized, continuous and timely.’
‘They always show commitment and formality with their clients, they make the matters entrusted to them their own and with this the client has absolute peace of mind that they are correctly attended to. Partners to highlight Daniel de la Parra and Manuel Sainz.’
Corporate powerhouse Creel, García-Cuéllar, Aiza y Enríquez, S.C. remains at the forefront of the tax sector in Mexico, offering its clients cutting edge expertise on matters related to M&A, financial services, projects, and debt and equity capital markets. It is also the go-to firm for publicly traded and private funds engaged in private equity, real estate, infrastructure and energy, and also handles transfer pricing (focused on transactional and high-value work), social security and wealth planning, as well as representation before the tax authorities. Alejandro Santoyo, who excels when advising on financial matters, heads the 28-strong standalone team that comprises specialists in tax advisory, litigation and controversy, transfer pricing, cross-border transactions, social security and wealth planning. Partners including ‘fin-tech expert’ Omar Zúñiga; capital market transactions-focused Jorge Correa (whose ‘approach and attention to the client are outstanding'); and skilled litigator Luis Vázquez, who specializes in cross-border matters, particularly in the application of tax treaty benefits, are all at the forefront in their specialisations. Moreover, the practice was further strengthened with the incorporation of the former head of the Taxpayers' Advocate Office (PRODECON) Luis Salinas, who joined as counsel in January 2020 and handles tax controversy issues. Other key practitioners include counsel Laura Frías, whose practice centres on transfer pricing, and senior associates Juan Mina and Eduardo Brandt.
‘Very strong team led by Jorge. Very responsive and advice is always thoroughly analyzed before sent out. Work product is of excellent quality. Luis Michel is a great associate with very rare excel modelling skills’
‘Professionalism, reputation and deep knowledge of the subject. Jorge Correa has experience that is difficult to find in other firms and his approach and attention to the client are outstanding.’
‘Eduardo Brandt and Omar Zúñiga are exceptional lawyers. They know the market very well and understand the international tax law that helps our business because we are an international company. They know the fin-tech sector, something few firms do nowadays.’
‘Creel’s tax lawyers act as an integrated team with key members of client staff. Regular status updates by phone and email and immediate contact when key developments happen. Strong negotiation skill and comfort with settlement situations. Keen awareness of corporate head office needs to demonstrate appropriate management of the particular client matter: awareness either by having worked in a corporate office setting; or constantly asking the client what additional information is needed from the firm to demonstrate appropriate management of the particular client matter.’
The Vanguard Group
Impulsora del Desarrollo y el Empleo en América Latina (IDEAL)
Ontario Teachers’ Pension Plan (OTPP)
JP Morgan Chase
Vista Oil & Gas
Newmont Goldcorp Corporation
- Acted as tax and M&A advisors to Ontario Teachers Pension Plan and Canada Pension Plan Investment Board regarding the planned tender offer for IDEAL shares, followed by a Fibra-E on its primary road assets.
- Tax counsel to BK Partners, the private equity firm controlling RLH Properties, on its acquisition of the Mayakoba Country Club project from OHL for an amount of $50m.
- Advised Campari on the $35m acquisition of a controlling interest in Mezcal Montelobos and Ancho Reyes from Casa Lumbre.
- Advised Gran Ciudad on the formation of an institutional real estate investment vehicle to fund the expansion of its multifamily rental housing property portfolio in Mexico for an amount of MXN$616bn ($313m approx).
- Represented White Summit Capital in connection with its $56m acquisition of two solar photovoltaic (PV) plants in Mexico.
Baker McKenzie Abogados, S.C.
The tax practice at Baker McKenzie Abogados, S.C. has a strong focus on foreign multinationals operating in Mexico, advising them on direct and indirect tax issues such as the tax authorities’ new approach to BEPS in auditing taxpayers, permanent establishment and transfer pricing adjustments for foreign companies operating nationally, the maquila program, tax disputes, and the tax implications of the county's energy reform legislation. The firm's five domestic offices, which host the team of over 70 lawyers, house a number of distinguished partners, including practice head Luis Adrian Jimenez-Robles, Luis Carbajo and Héctor Reyes, who undertakes tax assessments, tax litigation, tax planning, M&A transactions and corporate tax matters, including tax compliance issues; Jorge Narváez who acts on tax controversy, consultancy and transfer pricing; financial-sector expert and seasoned litigator Ulises Castilla; and both Moises Curiel-Garcia and Carlos A Linares-Garcia, who specialize in transfer pricing, all impress. Other key practitioners include Ciudad Juarez-based partner Juan Valles, Roberto Cardona and recently promoted Diana Juarez, who specializes in digital economy work, a thriving area for the firm over the past year.
Air Liquide Mexico
Elkay Interior Systems Latin America
Hospital y Clínica OCA
JR Simplot (Congeladora y Empacadora Nacional)
La Encantada Procesadora de Minerales
Minera el Pilon
Marriott (Hotel W)
- Defended Conmexco against a tax assessment derived from the company’s 2009 tax audit.
- Representing ITT Corporation regarding an assessed a tax deficiency of $7m due to allegedly incorrect usage of an offsetting mechanism in the payment of income tax.
- Represented Air Liquide Mexico with regard to the Tax Authority’s refusal to refund a favourable 2012 VAT balance.
- Assisted Marriott with the implementation of a legal strategy to settle several differences assessed by the Local Tax Authorities (regarding property tax for the fiscal year’s 2004 to 2019); value, $11m.
The 28-strong practice at Basham, Ringe y Correa, S.C. has market-leading expertise in tax controversy - especially regarding transfer pricing disputes; beyond that specialisation, it covers the full array of tax matters. Working closely with the firm's international trade and customs area, the department is highly regarded among relevant clients from the mining, automotive, retail, and energy industry. The team is led by five partners: skilled litigators Gerardo Nieto, Gil Zenteno and Alejandro Barrera, who also focuses on tax planning advisory and consulting, and tax strategy; Sergio Barajas, who leads the international trade and customs area; and corporate tax expert Victor Barajas. Francisco Matus, who specializes in financial taxation, was promoted to partner in March 2020. Senior associates to note include Maquiladora expert Roberto Serralde, and Eduardo Ramos, who has a strong background in finance and transfer pricing.
Olgoonik Technical Services México
Infrasestructura Energetica del Norte
Gasoducto de Morelos
Desarrollos Mineros San Luis
Herbalife Internacional de México
Tesa Tape México
Servilaminas de México
Desarrollos Mineros San Luis
IMM Research México
- Represented Goldcorp in a corporate restructuring from 2008, the tax authorities were unaware of the fiscal effects and determined differences of $470m; the team is defending Goldcorp and presenting a revocation appeal.
- Representing Walmart in the audit processes and inspection by the tax authorities derived from its sale of Suburbia to Liverpool.
- The team filed a conclusive settlement before the Attorney General for the Taxpayer Defense on behalf of Herbalife.
- The team filed an administrative appeal against a resolution which assessed Desarrollos Mineros San Luis with a tax liability of $7.6m for the fiscal year 2009.
The young practice at Galicia Abogados S.C. has repeatedly strengthened itself since its creation four years ago, and now fields a solid 17-strong team of professionals- including four partners - that specializes in matters such as tax consulting, tax controversy, alternative dispute resolution and tax litigation, and has particular strength in international tax matters and cross-border transactions. The department, which is combined with the wealth management area, is led by Gabriela Pellón, who is increasingly well known for her exemplary transactional tax work. Other key partners include Federico Scheffler, who also specializes in transactional tax mandates; Edson Uribe Guerrero, former deputy Chair of the PRODECON, where he was officer in charge of implementing and supervising the first alternative dispute resolution procedure (tax mediation) in Mexico; and Denise Lester, who was promoted to partner in January and focuses on tax litigation matters.
Citi/ Credit Suisse/ Itaú/ Santander/ Morgan Stanley
- Represented Grupo Bimbo in various due diligence processes intended to analyse operations carried by the company so as to determine the optimal way to continue complying with its tax obligations in the most effective and efficient manner.
- Assisted Blue Marine with the development of a project financing in which a bridge loan coexisted with the implementation of a tax lease to build a ship in Spain.
- Currently advising Tata Consultancy Services in connection with a restructure of the operations it conducts in Mexican territory.
- Represented InspirED in the structuring and negotiation of the company’s acquisition of a school located in Monterrey, Mexico.
The five-year-old tax practice at Nader, Hayaux y Goebel, SC was significantly bolstered during 2019 with the absorption of tax boutique Escalante & Asociados. The inclusion of tax expert Ángel Escalante as partner has increased the department's scope and capacity, and added additional expertise in the areas of international trade and anti-money laundering. Seasoned tax advisor, Adalberto Valadez, heads the four-strong team, that handles the tax aspects of high-end transactions and projects, including M&A and capital markets -particularly 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. Support comes from senior associate Alejandro Gordillo.
CKD Infraestructura México
Caisse de dépôt et placement du Québec
Altius Investment Group
- Advised BlackRock on the sale of its investment in Mexico’s first privately owned energy company, Sierra Oil & Gas.
- Represented Altius Investment Group in relation to the structuring of a joint venture with Mexican developers that will focus on residential and commercial properties.
- Advised Garrett Motion and its subsidiaries, as issuers and guarantors, on a €450m aggregate principal amount of senior notes.
- Advised ALS Global in connection with the tax aspects of the acquisition of Laboratorios de Control ARJ.
Ritch, Mueller, Heather y Nicolau, S.C. stands out for its forceful capabilities in transactional tax advice and for its sharp focus on litigation, while also handling day-to-day matters and tax planning. Oscar A Lopez Velarde, who is praised for his ‘extensive knowledge and understanding’, acts for clients, mostly from the energy, real estate, M&A and capital markets sectors, in a full range of contentious procedures, including administrative appeals, mediation procedures, annulment trials and amparo lawsuits. He co-heads the 18 strong team of lawyers and accountants in conjunction with Santiago Llano Zapatero, who specializes in transfer pricing and tax planning. Key support comes from senior associate Juan José Paullada Eguirao, who excels as a tax litigator.
‘Oscar López Velarde has extensive knowledge and understanding, prestige and excellent availability’
‘They cover international matters, fiscal issues on updates and possible reforms, not only in Mexico but in the countries with which Mexico has a relationship. It has a team with extensive knowledge of legal and tax issues that is difficult to compare with other accounting or legal firms. I would say that it can only be compared with a few recognized firms in Mexico’
‘Santiago Zapatero assisted me directly and was very kind’
Arias y Meurinne, SC
The sizable team at Arias y Meurinne, SC advises an impressive roster of clients, comprised particularly of players from the telecommunications, automotive and pharmaceutical sectors. While the practice is recognizsed for its profile and strength in litigation matters, including cases related to international taxation issues such as double taxation conventions and national provisions with international effect, it also performs well in the transactional tax market, counselling clients on the tax aspects of mergers, acquisitions, reorganizations and other relevant operations. Senior partner Pedro Arias (litigation and international tax planning matters), Pamela Orozco (tax, telecoms and administrative law), and Luis Eduardo Meurinne (tax planning and consultancy), head a team, that also includes Grupo Salinas' former director of tax litigation, Leobardo Brizuela, a 2018-arrival at the firm; and tax generalist Salvador González. Further support comes very active senior associate Leah Sánchez.
Ernst & Young
The tax practice at Ernst & Young assists with a broad range of compliance and tax planning matters, and is also known for its experience handling federal audit investigations, administrative procedures and resulting litigation. In April 2020 the department endured the departure of key partners Nora Morales and Enrique Ramírez, both highly-respected tax litigators, who joined Mijares, Angoitia, Cortés y Fuentes S.C. Nevertheless, with 12 offices across the country the organisation is a resilient player; the group retains impressive contentious-side capability, for example, in Manuel González and Antonio del Campo - that latter a former head of contentious matters for major contributors at the SAT. Dual-qualified in Mexico and New York, head of tax and legal services Manuel Solano is the key contact on the tax consultancy side. The practice also remains strong on international taxation. Former head of the private clients’ practice, Elias Adam Bitar left in October 2019 to establish a cross-border tax planning consultancy.
The ‘very good' practice at Jáuregui y Del Valle, S.C. is best known for its high level of expertise in tax consultancy work, particularly for real estate funds. Providing 'first-class attention', managing partner Luis Gerardo Del Valle Torres heads the team in conjunction with Eduardo Medina Zapata, who also has substantial experience in structuring venture capital, private equity and commodity funds on behalf of national and international fund sponsors. They co-lead a ten-strong practice, that houses a solid sub-department for tax litigation and arbitration matters, led by partner Luis Carballo Balvanera. Experienced associate Josemaría Férez Gil is also noted; but Patricia Schroeder exited to consultancy Gudiño Casas in June 2020.
‘They’re very good. Luis Gerardo del Valle is very creative and José María Ferez is very good at following up.’
Walton Street México
FINSA Real Estate Managament
Walton Street México CKD Managers
FINSA Real Estate Managament II
PGIM Real Estate
Advance Real Estate
- Advised Walton CKD II on the structuring of the acquisition of a hotel known as Pedregal located in Los Cabos, Mexico, to be operated under the Waldorf Astoria brand.
- Advised FINSA CKD II on the acquisition of a large industrial portfolio from FIBRA Prologis.
- Advised Fondo de Fondos and Afore Banamex on the structuring of a joint venture with other publicly traded funds to develop and operate the JW Marriot and Westin hotels in Monterrey.
Sánchez Devanny's international experience has given the practice substantial hands-on expertise in cross border tax matters. The 20-strong team is co-led by five partners: the experienced Ricardo Leon-Santacruz, who specializes in tax planning and transfer pricing; Guillermo Villaseñor-Tadeo, who leads on the litigation front; Luis Antonio González Flores, who has broad experience in national and international tax audits, anti-money laundering and anti-corruption compliance strategies, with a special focus on multinational enterprises; Mariana Eguiarte-Morett, who has ‘impressive technical knowledge on international tax matters’; and Abel Mejia-Cosenza, who specializes in international tax planning for both individuals and corporations.
‘The firm shows strength in foreign tax knowledge with national implications. In general they are very accessible, I can contact them by phone, mail or whatsapp and they are always willing to answer the doubts that arise in a process unknown to us.’
‘Sanchez Devanny’s team works collaboratively to find solutions and to deeply understand the business and the issues that come up with specific solutions. Also, they work fast without losing the quality of their work by involving senior and high capable professionals to deal with every matter.’
‘Mariana Eguiarte Morett has an impressive technical knowledge on international tax matters and an extensive international network to help dealing with impacts in multiple jurisdictions. Pedro Jose Miranda Sadurni has great experience on tax controversy matters and brings a lot of practical insights to assist on tax audits and litigation.’
Investar Capital Partners
H&M Hennes & Mauritz
- Advised Laboratorios Sophia on the design and implementation of an offshore private equity fund for the purpose of acquiring and participating in start-up and mature pharmaceutical companies and joint ventures, particularly in the US, Canada and in Asia.
- Advising Repsol on tax issues arising from the day-to-day transactions of Repsol in Mexico via intercompany transactions, and with customers and suppliers; as well as on the cross border transactions occurring mostly with Spain.
- Advised Ganamex on the identification and improvement of its business model, regulatory compliance and tax optimization plans and their operation.
SMPS Legal's tax consulting and litigation practice that handles a broad array of matters, including estate planning, acquisitions, mergers; corporate restructuring; and corporate and international taxation - particularly in connection with the real estate, private equity and oil-and-gas industries. The seven-strong team is co-led by four partners: Jorge San Martín, whose strong suit is tax efficient structures; Ana Paula Pardo, who has a very solid advisory practice; tax litigation specialist Christian Solis; and Alexis Michel, who manages all matters related to international trade. Key support, especially as regards litigation, comes from senior associate Jorge Arturo Rodríguez.
Fideicomiso Nexxus Capital VI (FICAP)
- Advised agro-industrial group Ecom regarding a tax audit which was successfully concluded this year.
- Representing Gerdau in a litigation procedure in relation to a wrongfully assessed tax credit.
- Advising Lufthansa Systems regarding the downsizing of its representation in Mexico, conducting the necessary procedures both before tax and regulatory authorities to change the status of a permanent establishment to a rep office with no income.
Turanzas, Bravo & Ambrosi
Independent boutique Turanzas, Bravo & Ambrosi remains as a strong choice in the tax realm. While focusing primarily on transactional tax matters, the practice - which includes seven partners - also manages tax litigation, representation before the tax authorities, international taxation, wealth management, and international trade and customs. Key partners include: Pedro Ramírez, recommended for his expertise in wealth management; and Mauricio Bravo and Angel J Turanzas Díaz who both handle corporate, indirect and local taxation and tax litigation, along with -respectively- estate planning and administrative litigation, respectively. Mauricio Ambrosi, who covers litigation and consultancy, with a focus on transfer pricing; skilled litigators Jorge Fuentes and Carl E Koller; and Francisco Ortega, who provides advice on corporate tax and representation before the tax authorities, as well as coverage of direct sales matters, are other names to note.
White & Case S.C.'s Mexican tax practice added new partners to its ranks in 2019, with the incorporation of Jorge Kim, former general counsel of Petróleos Mexicanos (PEMEX). He joins an eight-strong team led by the talented Guillermo Aguayo, who is praised for his expertise on corporate transactions, advising mainly banks and financial institutions. The group, which has particular expertise related to negotiations with the authorities to obtain VAT refunds, also has a solid focus in litigation, transfer pricing, complex audits and financial issues. Other noted practitioners include Ismael Reyes Retana, recommended as an outstanding litigator; and experienced associate Juan Ignacio López, who played a key role in the practice last year.
Acedo, Santamarina, S.C
Acedo, Santamarina, S.C has a ‘cost efficient, approachable and easy to work-with tax team, that understands the needs of the client perfectly, and delivers efficient and timely results’. According to clients, the department also offers a ‘fresh and innovative vision for the analysis of current fiscal and administrative issues’. The four-strong team, which is led by the ‘excellent’ Rafael Tena, 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 firm offers a fresh and innovative vision for the analysis of current fiscal and administrative issues. Contingencies are addressed in a clear manner and dispute resolution is developed in diverse scenarios to adapt costs to the client’s needs. All at a very competitive price’
‘Personalized attention, constant communication, study of variables according to the industry, effort to know the particularities of the client’s market’
‘Acedo Santamarina has a cost efficient, approachable, easy to work-with tax team, that understand the needs of the client perfectly, and deliver efficient and timely results. They avoid unnecessary complexities. Rafael Tena is the stand out partner in the Acedo Santamarina tax team’
‘Rafael Tena is always available for his clients, and provides insightful legal advice. He stays up to date with legal and regulatory developments, and knows how to translate those legal requirements into actionable advice for the client and the business side of the matters’
‘Knowledge of legislation and players. Ability to anticipate, plan and adapt to new regulations. Precision and detail in the communication of the requested information. Rafael Tena Castro is excellent’
Compañía Mexicana de Radiología
Ghenova Ingeniería México
Los Reyes Industrial
Payán Campos Hnos
PRGX de México
Top Victory Electronics de México
Ventas Joyma del Sur
Vicrila Glass Manufacturing Company
- Represented Cinematrográfica Filmex in a nullity trial against tax authority SAT.
- Advised Compañía Mexicana de Radiología CGR on the appropriateness of challenging an official communication issued by the Ministry of Economy, through which general rules and criteria on foreign trade were changed.
EC Legal Rubio Villegas houses a 10-strong group of experts in international taxation who offer an excellent combination between tax planning and litigation. Operating from the firm's six offices across the country, the practice has a solid reputation for its expertise in the maquiladora industry, the interpretation and application of tax treaties, including the analysis of permanent establishment and taxation of residents and expatriates to avoid double taxation. Key partners include: Edmundo Hernández and Arturo Bañuelos, who mostly handle litigious matters; Felipe Mendoza, who is dedicated to tax planning with a more international focus along with the maquiladora industry; and Fernando Holguín, who focuses in taxation, customs and international trade.
‘Commitment, analysis of the details, technique and legal experience’
‘Edmundo Hernandez is an innovative professional, with well-founded arguments, who gets involved in the operation. He is always available and attentive to the client’s needs. He transmits confidence and determination in the decisions that need to be made’
After notably reinforcing its team in 2019, the tax practice at Garrigues endured the February 2020 departure of department head Santiago Chacón, who led on the tax advisory front. Departmental leadership has been taken over by Manual Llaca, who joined the firm in May 2019, and heads the team handling litigious tax matters; he specializes in transfer pricing matters, litigation regarding federal taxes and dispute resolutions. The eight-strong team, which can also rely on the firm's international network, includes highlighted senior associates: Ricardo Fernández de Arellano, who focuses on international tax, litigation and tax planning as applied to Spain, Mexico and the United States; tax controversy expert Francisco Barajas; and Diego López, who specializes on tax advice for foreign companies expanding into Mexico, tax planning for corporate restructurings and M&A, and in value supply-chain transformation projects.
‘They have a good knowledge of the law, pay attention to detail and are proactive. They are highly-experienced, structured and well-organized professionals. They have a lot of experience advising business people and understand their problems and are therefore used to seeking efficient solutions’
‘They are always available to answer questions, they know how to listen to different concerns and opinions’
Talma Servicios Aeroportuarios
Sony Music México
El Corte Inglés
Cerealto CIRO Foods
- Assisted Talma in the tax planning for the acquisition of 95% of Varig de Mexico, a subsidiary of a Varig Brazil, an airline that declared bankruptcy in 2006.
- Advising CIRSA in an ongoing dispute between the company and several District and Administrative Courts, regarding a state local duty applicable to gambling companies.
Mexico City-based partners Arturo Tiburcio, and Jaime Espinosa (who also operates from the Monterrey office), co-head the 12-strong practice at Hogan Lovells. In tandem, the pair constitute an impressive offering with significant expertise in income tax and double tax conventions (transactional and cross border operations), VAT in the exportation of services, and indirect taxes, as well as disputes, social security and wealth management. They also advise clients -particularly from the transportation, food, and services industries- on transactions and before the authorities. Support comes from Francisco Palmero; promoted to counsel in January 2021, he focuses on audit procedures, consulting and litigation.
NYK de México
Cushman & Wakefield
Conservas la Costeña
Central American Bottling Corporation (BIA Foods)
- Represented DHL Global before the tax authority in relation to an audit procedure and defence of the company regarding a sanction from the tax authority.
- Advised Cardone Industries regarding its operations in Mexico, as well as assisting the company in several audit procedures before the tax authority and conclusive agreement procedures before PRODECON.
Jones Day fields a small, but robust practice, that handles handles a broad range of tax issues, with strong skill sets in both contentious and transactional matters. Particularly renowned for its long-established experience in advising regulated industries -principally oil and gas, telecommunications and transportation- the department, which is backed by the firm's international network, is led by partner Rodrigo Gómez. An expert on all aspects of federal and international Mexican taxation, including the tax aspects of M&A transactions, restructurings, and financial instruments, Gómez also represents clients in tax disputes, including audits, appeals, and settlement processes.
Lixil Group / American Standard
The Haskell Company
- Advised PolyOne Corporation on the $775m cash sale of its performance products and solutions business to SK Capital Partners.
- Advised Crédito Real regarding the issuance of €350m ($382m) of Senior Notes due 2027.
Ortiz Abogados Tributarios S.C.
Experienced tax boutique Ortiz Abogados Tributarios S.C. has established itself as a noteworthy player in the market, especially for its litigation practice. Seasoned partner Gabriel Ortíz, a reference within the tax arena for his controversy expertise, heads the department, supported by key partners Carlos Yáñez Alegría, Carlos Monarrez, and Pablo Ramírez.
Ortiz, Sosa Y Asociados, S.C.
Accountancy and tax advisory boutique firm Ortiz, Sosa y Asociados, S.C., is recommended for its impressive breadth of tax expertise, which covers a wide range of matters including tax consultations, transactional tax advice, valuations and optimization, legislative guidance, and dispute resolution. Clients value the team's ‘technical and practical knowledge’, as well as its ‘impeccable’ and ‘very accurate’ level of attention and advice. The 13-strong practice, made up of both lawyers and accountants, is led by the ‘very competent’ Miguel Ortíz, in conjunction with Luis Curiel, who leads on litigious matters. Other key practitioners include Ignacio Sosa, who focuses on corporate tax; José Manuel Trueba and tax consulting expert Jorge Ricardo Flores.
‘The team at Ortiz, Sosa y Asociados is very professional. Their attention and advice are impeccable and, in my opinion, always very accurate. They always have an excellent disposition. Miguel Ortíz is an excellent advisor, very well prepared, and always very friendly’
‘I would highlight the synergy between accountants and lawyers to understand the needs of the requirements. Technical and practical knowledge, personalized attention, from the team and from partner Luis Curiel Piña’
‘Miguel Ortiz (and his team) are very complete and ethical professionals, who provide tax strategies in accordance with the applicable legislation, with clear and precise communication. Miguel Ortíz is a very competent professional with important communication and leadership skills’
‘They have the right team for strategy issues (Miguel Ortiz) and legal issues (Luis Curiel) which generates confidence in their recommendations which are always well-founded and propose creative but legally sound alternatives’
‘Miguel Ortiz is always available to take our calls or invitations to meetings, which makes his recommendations always timely’
Grupo Financiero Interacciones (GFInteracciones).
Grupo Mexicano de Desarrollo
‘Big four’ giant PricewaterhouseCoopers, SC is an important player in the Mexican tax realm thanks to its broad offering of diversified tax consultancy and representation. Operating from its ten offices across the country, the practice includes noted practitioners managing director Jesus Francisco Morales, José Ricardo Soto, Luciano Scandolari, Sandro Castañeda, José Antonio Garduño and Carlos Manuel Martinez.
The six-strong tax practice at full-service firm Santamarina y Steta, renowned for its litigation capabilities, is led by experienced partner Mariano Calderón, who specializes in tax, constitutional and administrative litigation, taxation, foreign trade and anti-money laundering matters. Other noteworthy practitioners include Karina Robledo, appointed counsel as of January 2021, who focuses on domestic and international tax matters - mainly acquisitions (due diligence), transfers, mergers, spin-offs and all types of corporate reorganisation; and senior associate Jair Vaca, who is very active on the litigation side.
‘Constant updating with respect to applicable legislation and tax authority criteria. Mariano Calderon: Proposes several strategies with an excellent risk analysis. Jair Vaca: Monitoring and attention to the matter. Naomi Tanaka: Monitoring and attention to the matter’
General Motors Mexico
Idemia (formerly: Morpho)
- Represented General Motors de México in tax litigation, including preparation and filing of writs and responses for a tax audit regarding a transfer pricing issued in 2008 and involving the company’s export operations and major deductions.
- As part of the acquisition of iZettle, PayPal acquired certain Mexican assets from the target’s Mexican subsidiary; the team advised on the tax implications of said assets on the purchase.
Market opinion considers Von Wobeser y Sierra, SC to have a very good and growing practice. Under the leadership of experienced partner Fernando Moreno, the team evidences notable strength regarding double taxation and other negative fiscal implications for foreign and national companies, as well as on the development of tax legal strategies for the restructuring and expanding of their clients' businesses via subsidiaries in Mexico and Latin America. Support comes from active senior associate Jorge Díaz, who also has extensive expertise in international trade & customs.
Procter & Gamble Mexico
Nu Skin Mexico
Cimentaciones Mexicanas (CIMESA)
- Advised BMW on several tax-related matters regarding the negotiation, building investment and now operation, of a luxury car factory in San Luis Potosi, Mexico.
- Represented a well-known entertainment business in Mexico which required specific legal tax expertise to expand its presence in the specific realm in which it operates.
Big-four player Deloitte Legal Mexico has a sizeable presence in Mexico with, the 60-strong tax controversy practice sitting within a broader 'tax and legal' team twice the size, with an offering that ranges from banking, corporate and IP to labour, projects and real estate. With a wide presence across the country, the department houses a number of noted practitioners including head of the tax controversy practice, Mauricio Martínez; and skilled litigators Carlos Alberto Ramirez and Ricardo Santoyo, who work from Monterrey and Mexico City respectively. Hugo Romero is also noted. Beyond the contentious segment, double taxation expert Eduardo Revilla; and Jorge Antonio Jimenez, who focuses on general corporate taxation, VAT, international taxation, double-taxation treaty application, customs law, and tax audits; are key figures. However, Raciel Flores , left the firm in June 2019 to establish TCLex Abogados.
Working closely with its US office network, the reputable tax practice at Foley Arena has strong expertise in tax planning, transfer pricing, tax mediation and litigation, along with administrative and constitutional challenges, negotiations to obtain tax incentives, customs regulations and audits. Roberto Arena, who specializes in treaty structuring, M&A, real estate, corporate restructurings, and litigation, co-heads the team together with Fernando Camarena, who is experienced in issues affecting foreign -particularly US- corporations, joint ventures, and country-specific treaties on double taxation.
International Game Technology (IGT)
Samuel, Son & Co
Value Oriented Services
Standarization and Certification
- Represented Herbalife in several high-profile litigations with respect to tax asessments for VAT on the importation of food supplements.
The Mexican tax practice at full-service U.S. firm Haynes and Boone, SC, specializes on cross border matters - with a particular focus on the oil-and-gas sector - including corporate and M&A, finance, real estate, and shipping, as well as audits and challenges before the authorities. The four-strong department is led by partner Edgar Klee who is well regarded among his peers for his expertise in non-contentious tax matters, offering corporate tax advice on international taxation, tax counselling for individuals, and customs and foreign trade, among other matters.
FCC Servicios Industriales y Energeticos
NextEra Energy Resources
Tresmontes Luccheti Mexico
- Represented equity owners of Corporación POK, on the sale of stock to Nucor Corporation.
Senior associate Eugenio Grageda heads the young tax practice at Holland & Knight, which is praised by clients for providing ‘the best solutions, especially when it comes to international issues’ and for their ‘knowledge of the subject, clarity of opinion and speed of delivery’. The small team, which is backed by the firm's international network, has ‘great capabilities’ advising on corporate reorganizations, 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, estate tax and succession planning.
‘Strengths: knowledge of the subject, clarity of opinion and speed of delivery. They compare favourably because usually the topics we deal with are complex and not all firms have the necessary knowledge or experience, as well as in the delivery times, which can be very long.’
‘Eugenio Grajeda, Luis Rubio, Blanca Luevano, Selene Espinosa Knowledge, are fluent in other languages.’
‘It’s a small team, but with great capabilities. As a family business I need to work with many firms as clients sometimes already have a tax lawyer. However, when they do not, I refer them to the Holland Knight team in Mexico. They have always provided the best solutions, especially when it comes to international issues.’
‘They definitely compare to other firms, even if their team is not very big. I would highlight their good ideas in general and Eugenio Grageda in particular.’
Mijares, Angoitia, Cortés y Fuentes S.C. has undoubtedly bolstered its tax offering with the April-2020 incorporation of renowned tax-litigation heavyweights: Nora Morales and Enrique Ramírez, who joined from Ernst & Young to handle tax controversy matters. Morales, who focuses on transfer pricing, tax treaty benefits and financial entities; and Ramírez, who is well-versed in tax planning and audits, co-lead the team with fellow partner Manuel Tamez, who heads up the consultancy side, and specializes in tax planning, consulting, M&A, securities and financing. The 14-strong department, comprising lawyers and accountants, has a focus on large foreign and Mexican multinationals from the manufacturing, energy and consumer sectors.
Ortiz, Hernández y Orendain, S.C.
Ortiz, Hernández y Orendain, S.C. is well-known in the tax arena for its tax controversy department, as well as for its expertise handling a wide range of matters including transfer pricing, audits, transactional matters, tax strategy, social security, tax refunds, and international taxation. The practice is led by deeply-experienced name-partners, Ignacio Orendain, Luis Ortiz-Hidalgo and Gerardo Hernández.
Rizo, Erreguerena y Garza-Cantú, S.C.
Founded in 2013, tax boutique Rizo, Erreguerena y Garza-Cantú, S.C., has steadily consolidated its small but sturdy practice, comprising noteworthy practitioners who handle a full range of consultancy work, representation before the tax authorities, and litigation on tax and administrative matters, including before constitutional courts. All three name partners are relevant practitioners: tax consultancy specialist José Miguel Erreguerena Albaitero; Juan Carlos Rizo, who spent over 10 years at the SAT handling litigation and amparo cases; and Carlos Garza-Cantú who also worked at the tax authority for over a decade, undertaking domestic and international tax matters.
Thompson & Knight LLP offers ‘tailor-made service’ on tax issues associated with corporate reorganizations, joint ventures, financing, mergers and acquisitions, spin offs, and inbound and offshore investments. Practice head Mario Barrera also represents clients before the tax authorities in audits, settlements, rulings, and mutual agreement procedures. The practice has a strong focus in the energy sector but also covers mining, real estate, pharmaceuticals and finance, among others.
‘Professional and tailor-made service.’
‘Mario Barrera stands out for his professionalism and technical knowledge.’
‘They are practical and creative in finding solutions. They are available when needed.’
Japan Tobacco International
- Advised a global insurance company in a tax examination and subsequent procedure to settle issues associated with a transfer pricing adjustment, disallowance of deductions based on cost sharing agreements, and other international taxation issues.