Tax in Peru

Hernández & Cía

Tax law powerhouse Hernández & Cía. Abogados continues to lead the way in high-end mandates for a stellar client base, acting for some of Peru's largest companies on the tax aspects of large-scale transactions, strategic tax planning or in contentious battles with tax authority, SUNAT, for example. The team also has capability in international tax law and cross-border tax planning. Pre-eminent tax lawyer Luis Hernández Berenguel plays an integral role, leading on multiple matters, while the team also boasts four other partners. They include fellow co-heads of the practice Milagros Bustillos and Leonardo López - contentious administrative tax matters and tax, customs and international trade, respectively; and corporate tax specialist Fernando Nuñez. Demonstrative of the team's success, it expanded considerably during the past year, hiring new partner Rodrigo Flores from CMS Grau and two new associates from competitor firms, including senior Julio Saenz. However, counsel Roxana Terrones moved to Picón & Asociados in February 2020.

Practice head(s):

Luis Hernández Berenguel; Milagros Bustillos; Leonardo López

Testimonials

Solid tax legal knowledge and wide and recognised professional experience.’

‘A stand out feature is the clarity of their arguments and presentation of legal scenarios, which impact on other professionals and our company’s senior management.’

What makes this practice unique is the provision of immediate attention, as well as knowledge of our sector. Strengths: technical and jurisprudential knowledge. Skills: offering alternatives. It compares favourably with the services of other firms.’

The plus that makes them stand out is the technical knowledge, the experience, as well as the collaboration of the partners. This is the case of Fernando Nunez.’

Confidence in professional sufficiency. We accept and implement the advice and reports of Hernández & Cía with the security generated by the high level of knowledge in tax matters of its members. It stands out from other teams from other firms. ‘

Milagros Bustillos serves us directly. The treatment is fluid, personal and from the point of view of knowledge an outstanding experience. The difference with other competitors is in the security they offer us. We value the opinion and advice of this firm.’

Good communication, knowledge of the issues giving confidence and sense of urgency as well as belonging, generating satisfaction with the definitions or solution plans to possible problems.’

I would highlight the sense of belonging and speed of response.’

Key clients

The Carlyle Group

Colony Capital

Grupo Wiese

Falabella Group

Procter & Gamble

Perupetro

Instituto Peruano de Acción Empresarial (IPAE)

AB InBev

Metrocolor

Petrex

Interbank Group

AJEPER

Grupo Telefónica

Owens-Illinois

Instituto Cultural Peruano Norteamericano

Lumina Copper

SES Satellite

Seven Seas Water

Sacyr

Dragabras Servicos de Dragagem

Perupetro

Dole – Peruvian subsidiaries

Petrex

Compañía de Minas Buenaventura

Banco Interamericano de Desarrollo (BID)

Barrick Gold – Minera Barrick Misquichilca

SES Satellite

Andino Capital

Constructora Cheves

Corporación ADC

Sociedad Minera de Responsabilidad Limitada Chaupiloma Dos de Cajamarca

LSA Enterprises Perú (now Riberas del Mar)

Work highlights

  • Advised The Carlyle Group on the design and execution of the transfer of its controlling package in Hermes Transportes Blindados (Hermes), in favour of CVC Capital Partners Fund VII.
  • Advised the Falabella Group in the reorganisation if its real estate, retail, financial and insurance brokerage businesses.
  • Represented Telefónica del Perú in various impugnation proceedings and appeals against the National Superintendence of Customs and Tax Administration (SUNAT).

Philippi Prietocarrizosa Ferrero DU & Uria

Philippi Prietocarrizosa Ferrero DU & Uria has a leading presence in this field, the result of deep expertise provided by well-known tax practitioner Walker Villanueva and his team. The firm excels on all aspects of contentious and non-contentious tax matters, attracting an enviable client base which saw some impressive additions during the year, including Credit Suisse, Liberty Seguros and online-shopping company Cornershop. In terms of recent mandates, headline client Telefónica del Perú sought advice in relation to a new service, enabling the firm to showcase its cross-border tax planning capability. The 16-strong team also includes international tax specialist Dante Sanguinetti and tax litigation director Carlos Moreano; while additional names to note at associate level include Johana Timana, elevated to practice director in July 2021, and principal Milagros Pastor, both of whom are in demand for client teams on key mandates.

Practice head(s):

Walker Villanueva; Dante Sanguinetti; Carlos Moreano

Testimonials

The tax team is highly committed to the objectives that the company sets and offers solid solutions to problems that arise. The results obtained so far with PPU are superior to those we have had with other law firms of supposedly similar standards.’

Dante Sanguinetti is a deep connoisseur in tax and general matters and in particular of our industry. He has advised us extensively in negotiations, fundamentally on the purchase of companies, always preserving our interests and minimising exposure to tax contingencies.’

It has a multi-sectoral team which know the standards of various sectors, which is beneficial for the consultancy they carry out. They always present the best possible solutions to problems.

They show a lot of empathy with their clients, they make the problems we have their own and they look for quick and innovative solutions. Walker Villanueva and Milagros Pastor are recommended.’

Key clients

Urbanova Inmobiliaria

Productos Tissue del Perú (PROTISA)

Breca Group

Telefónica del Perú

Scania Services

Lindcorp

Rimac Seguros

Cornershop

Mckinsey & Company (Peru branch)

Credit Suisse

Liberty Seguros

LATAM Airlines

Corporacion Meier

Secrex

Tecnología de Materiales

Ilko Peru

Work highlights

  • Advised LATAM Airlines Peru on specific tax issues arising from developing its operations in the country, and in respect of related parties, as well as sponsoring the client before the Peruvian Tax Administration regarding tax procedures to the sum of  $116m.
  • Advising Telefónica del Perú on the development of a new service that involved cross-border activities and ongoing advice concerning contentious tax issues.
  • Acting for Corporacion Meier in relation to the tax impact of expanding its gambling activities, considering recent legislative changes that increase the taxes in that industry.

Rodrigo, Elías & Medrano – Abogados

The tax offering at Rodrigo, Elías & Medrano – Abogados remains hard to beat for lawyer numbers and expertise. Some nine partners are focused on the sector, ensuring all aspects of commercial tax are covered, with stand-out strength in complex and cross-border transactional support and litigation. A diverse client portfolio reveals broad industry knowledge, essential for strategic tax planning, which the firm provides to a host of prominent domestic and international companies. Co-head of the practice Alex Córdova is a market-leading corporate tax partner, with niche expertise in extractive industries, while fellow co-head Alex Morris is an authority on tax planning and international fiscal transparency and leads the wealth-management side of the practice. Other names to note include: Tulio Tartarini, who specialises in utilities taxation, among other areas; corporate tax adviser Mariella de la Torre; and the more junior partner Raúl Hidalgo.

Practice head(s):

Alex Córdova; Alex Morris

Key clients

Minera Las Bambas

Minera Chinalco Perú

Luz del Sur

Telefónica del Perú

Tiendas por Departamento Ripley

Corporación Lindley

Huawei del Perú

San Fernando

Compañía Minera Antamina

Southern Perú Copper Corporation Sucursal del Perú

Work highlights

  • Acted as local counsel to Sempra Energy International Holdings in the sale of a majority stake in Luz del Sur to China Yangtze Power International (CYPI), an entity controlled by China Three Gorges Corporation, including all the tax implications of the sale and transfer of shares.
  • Advising Minera Las Bambas in tax proceedings before the Peruvian Tax Court corresponding to several fiscal years, determining whether resettlement expenses incurred by the client should be considered as development expenses or as a part of the acquisition cost of the land.
  • Acted as local counsel to CVC Capital Partners on the tax aspects of its $400m acquisition of Peruvian company Hermes Transportes Blindados (Hermes) sold by The Carlyle Group.

Zuzunaga, Assereto & Zegarra Abogados

The most established among the growing number of tax law boutiques, Zuzunaga, Assereto & Zegarra Abogados offers considerable depth, both at a resources and capability level. A 20-strong team of tax law specialists provides the full-spectrum of tax advice, from litigation, consulting and tax planning, through to international taxation and foreign trade. Evidencing the firm's continued success, headline companies Alicorp and Compañía de Minas Buenaventura were just two of several high-profile client gains during the past year. A roll-call of five expert partners includes Fernando Zuzunaga Del Pino, a leader in corporate tax and international investment; Juan José Assereto, whose areas of expertise include infrastructure projects and litigation; extractive industries expert Juan Carlos Zegarra; litigator Lorgio Moreno; and the more junior partner Luciana Yañez. Sergio Vega León moved to Deloitte in February 2021.

Practice head(s):

Fernando Zuzunaga Del Pino; Juan José Assereto; Juan Carlos Zegarra; Lorgio Moreno; Luciana Yañez.

Testimonials

Zuzunaga, Assereto & Zegarra Abogados, is a boutique-type firm specialised in tax and customs matters whose characteristics mean that it can focus on providing a dedicated service, very professional, with a lot of experience and fundamentally, with a deep knowledge of its specialty . Thus, it can be mentioned that it has staff that comes from the tax authority itself, which gives it a very important ‘plus’.’

‘Main strength is their experience and very deep knowledge. The fact of having partners and managers who come from working in the tax authority itself, in the area of ​​examination, claims and litigation, is what makes this firm stand out. Among those who serve us with great knowledge, proactivity and professionalism, I can mention Juan José Assereto, Socorro Núñez and Tania Albarracín. They are really excellent and outstanding.’

Key clients

Autoridad para la Reconstrucción con Cambios (ARCC)

Minera Barrick Misquichilca (Barrick Group)

Fluor Group

Gas Natural de Lima y Callao (Cálidda)

Kallpa Generación

Minera MMG Las Bambas

Cumbres Andinas (Breca Group)

Fenix Power

Alicorp

Inversiones Logísticas Limitada (Ultramar Chile)

Work highlights

  • Advised Cumbres Andinas and Marcobre on the fulfilment of the $563m investment that Cumbres Andinas made in Marcobre’s capital stock, in accordance with the Legal Stability Agreement signed with the Peruvian State.
  • Advising government body Autoridad para la Reconstrucción con Cambios (ARCC), created and assigned to the Presidency of the Council of Ministers, to lead and execute the reconstruction plan to benefit the region affected by El Niño phenomenon in 2017, including the possible tax impacts of the provision of services by non-domiciled suppliers.
  • Advised Gas Natural de Lima y Callao – Cálidda on litigation procedures before the Tax Court, related to income tax regarding the deduction of amounts established in settlement agreements.

Damma Legal Advisors

In just over two years, tax boutique Damma Legal Advisors has established itself as a credible alternative to large full-service firms and boasts a client list the envy of many competitors. Deep and broad expertise at partner level is delivered by four experienced professionals, all former heads of departments at well-known firms, who jointly lead an eight-strong team.  Iván Chu is recognised for corporate tax, including M&A, and banking and finance projects, while Walther Belaunde has an expansive practice that includes corporate reorganisations with specialism in the mining industry. Jose Chiarella shines for private client advisory work and the high-profile Rocio Liu is strong across the board but is particularly known for tax litigation. Since publication, the firm has indicated its intention to move beyond its specialisations in tax and labour matters with the February-2022 hire of Juan José Cardenas, formerly at EY Peru, as head of the nascent corporate-transactional and projects & infrastructure practices.

Practice head(s):

Walther Belaunde; Ivan Chu; Jose Chiarella; Rocío Liu

Testimonials

The tax advice is first class. The lawyers have a lot of experience and are very knowledgeable about the different economic sectors and the rules that specifically regulate their activity, which allows them to provide very specialised advice. They are very meticulous and precise, which makes them ideal for advising on complex issues.’

I especially appreciate the dedication and professionalism of Rocío Liu, who attends us personally. Her work is impeccable.’

Damma provides us with an immediate and dedicated service. Their deep knowledge of the company and the sector, as well as their constant monitoring of the tax authority, allows them to provide us with solid answers to the different issues that arise.’

Their thoroughness and preparation stand out. Their opinions and advice are well analysed before reaching us.’

Excellent.’

Great knowledge in tax matters and unlike other law firms, they go directly to their recommendation in an objective way, putting themselves in the client’s situation. Jose Chiarella is a partner and tax specialist of the firm, he is recognised as an excellent person, professional, very prepared in the matter and always available to answer any questions and concerns.’

They know the mining business for their extensive knowledge and experience in the sector. In Peru, this branch of tax law has many sectoral regulations that must go hand in hand with tax matters.’

Walther Belaunde is excellent in knowledge and experience in the mining-tax sector.’

Key clients

Southern Peru Copper Corporation

Lima Airport Partners

Luz del Sur

Sacyr Construcción Perú

Cerámica San Lorenzo

Reyemsa

Joy Global Perú

Belcorp

Algeciras Inversiones

Engie

Cementos Pacasmayo

Enel Peru

Laboratorios Roche

Hunt Oil

Enfoca

Grupo Romero

Intercorp

Chilles & Benson

Inkia Energy

Seabord Corporation

Hub1916

Química Suiza Industrial

Camposol

Work highlights

  • Representing Enel Distribución Perú in three different tax lawsuits before the Peruvian judiciary, concerning tax assessments made by the Peruvian tax authorities with respect to the deductibility of losses of energy for income tax in 2009, 2010 and 2011.
  • Provided tax and corporate advice to Química Suiza Industrial and its parent company on the structuring and execution of two complex corporate reorganisations involving the rearrangement of the corporate structure and the spin-off of a specialised line of business to a related company.
  • Acted for sportswear company Hub1916 on the restructuring of its Peruvian operations through its local subsidiary, which aimed to increase the tax efficiency of the Peruvian operations, and increase the liquidity flow needed to carry out the business.

Estudio Echecopar member firm of Baker McKenzie International

Estudio Echecopar member firm of Baker McKenzie International stands out for its cross-border transactional capability, of particular value for the firm's many multinational clients. It also provides day-to-day tax advice and judicial and administrative litigation across a broad industry base, including banking, healthcare, retail, agribusiness, digital, mining and energy, and construction. Head of the team Rolando Ramirez-Gaston is a versatile practitioner, advising across all aspects of commercial tax and wealth management; he is now sole partner of the practice following the departure of Erik Lind in October 2020, but is supported by plentiful seniority at associate level in principals Carla Peirano Castañeda, Dora Ramos Traverso and Cristina De la Piedra.

Practice head(s):

Rolando Ramírez-Gastón

Testimonials

Extremely bright team with a speciality on structuring international transactions. They understand the local issues as well as international tax structuring issues. They are great at issue spotting which is exactly what in-house counsel needs.’

Rolando Ramirez-Gaston has to be the brightest tax attorney in Peru.  Smart as a whip, he has the capacity to absorb information quickly and solve tax issues with creative solutions.  He is supported by Cristina de la Piedra, an upcoming rock star who is easily able to understand complex tax issues and propose solutions.’

Technical knowledge, clarity when answering the query, efficiency and timeliness of responses.’

Interest in the client’s business and focused on giving alternatives that allow finding solutions to the problems raised.’

What makes the tax practice unique for us is that the lawyers we hire understand our business and, relying on current regulations, can advise us in the best way. It does not help me that they know about tax if they do not know how to apply it to my business and what is in my best interest financially. The Estudio Echecopar team stands out among other firms favourably in this regard.’

I can particularly highlight Rolando Ramirez-Gaston, who is practical when explaining complex tax issues to us and how they affect us in our particular business, which is very complex.

It is a team that has knowledge of local tax issues but with a corporate vision and this point is extremely important for us. Yes, I have very good experience with the firm – they are direct, concrete and decisive.’

They immediately capture the need and are practical, direct and objective about the solution proposals.’

Key clients

Herbalife

Derco

Explora Hoteles

IBT

Grupo IF

Banco Santander

Braskem

Sodexo

Logicalis

AFP Habitat

Ajeper

Larrain Vial

Cepsa

Crowncorck

Unilabs

Traxys

Parque Arauco

Gloria

Work highlights

  • Advised Amcor on tax planning related to a potential regional corporate reorganisation, including Peru, Panama, Chile, Argentina and Colombia.
  • Acted for Quimtia, a regional leader in the sale and distribution of chemical products, on tax planning concerning a corporate reorganisation, in order to obtain the most efficient corporate tax structure.
  • Supported Cepsa, the non-domiciled Peruvian parent company, on tax basis certification proceedings in order to transfer its shares to Cepsa Peru.

EY Peru

Tax law permeates through the entire business at EY Peru, which fields an extensive team comprising specialists across the entire spectrum of tax issues, including advisory, compliance, litigation, international and domestic transactions, private client and transfer pricing. Office managing partner David de la Torre heads the practice, although the majority of key mandates are led by partner colleagues, in particular: Marcial Garcia, head of transfer pricing; international tax and transactions specialist Fernando Tori Vargas; tax litigators Maria Eugenia Caller and Percy Bardales; and head of tax infrastructure Manuel Rivera.

Practice head(s):

David De la Torre

Testimonials

A very dedicated and knowlegeable team. Practical and to the point. They know their business and what to do.’

Fernando Tori and Edwin Sarmiento form a good and balanced team that have a good harmony and know what to do and how to deal with the matter. Highly recommended.’

The link with the other areas of EY is very important in order to provide a more comprehensive and detailed service.’

Business and multidisciplinary vision.’

EY has a staff of first-rate professionals who penetrate the very operation of my business, seeking to proactively offer solutions in a consistent manner, becoming a long-term strategic partner for us. I think what sets them apart from other practices is their comprehensive and long-term relationship focused angle.’

Manuel Rivera is the partner who manages the relationship of the tax practice with my company. I highlight his in-depth knowledge of current regulations, his knowledge of similar cases in a multiplicity of organisations in the country and abroad, his connection with offices in other countries where my company also operates, and his permanent disposition to listen to what we need and provide solutions. Similar behaviour is observed in Yessenia Burga, the manager who works on my account.’

In the EY Peru team, I highlight the work of partner Humberto Astete, who is very close to his clients, giving personalised advice. Very reliable and a good adviser.’

Like any large firm, quality is made by people, and I can only highlight the work of Humberto Astete.

Key clients

SHV Holding Group

American Tower Corporation

Volcan

Credicorp Capital FIBRA

Saint-Gobain Group

Delivery Hero

MIQ (Noatum)

Mace

Tiendas Peruanas

Work highlights

  • Advised SHV Holding Group on its Peruvian divestiture, value $360m.
  • Provided tax advice to American Tower Corporation on the due diligence and structuring for the acquisition of Telefonica’s regional business line held by Telxius; total deal value $9.4bn.
  • Representing Volcan in its defence strategy in litigation to nullify the Tax Administration’s thesis (VAT taxation of Holding Certificates), reducing the debt and managing the risk of enforceability, value approximately $428m.

Muñiz, Olaya, Meléndez, Castro, Ono & Herrera Abogados

The team at Muñiz, Olaya, Meléndez, Castro, Ono & Herrera Abogados focuses on tax planning and optimisation to avoid contentious dealings with the tax authorities. It is also able to advise more widely on all fiscal matters, including tax compliance, audits, litigation, advisory, and M&A and financial transactions; notably the firm also offers transfer pricing advice via sibling entity Muñiz Transfer Pricing. Internationally-trained Fernando Castro focuses on corporate transactions and leads an experienced team of 18 lawyers. Fellow partners include: Daniel Ono, who has a focus on the automobile, industrial, pharmaceutical and consumer products sectors; transactional specialist Jorge Otoya; and Luis Garcia, who handles tax audits, among other matters.

Practice head(s):

Fernando Castro

Testimonials

Well structured tax team.

Jorge Otoya is best in class by far. Very detail-oriented and knowledgeable of tax matters.

Quality team with a lot of empathy; Fernando Castro is the one who attends us.’

Luis Garcia makes his area stands out: his quick and efficient response capacity as well as the knowledge of his client distinguishes his practice.’

It is unique in that is is very proactive and engages with the needs of clients. Fernando Castro is recommended.’

The lawyers who attend us have known us for many years and know what we want as a company, what our goals are and how they can help us to achieve it. They are always with us before any examination before the Tax Administration.’

Luis García and Jorge Otoya are the ones who permanently support us in tax matters. The plus is that they are always there when you need them.’

Key clients

Ericsson

Maersk

Harvard Management Company

Banco BBVA Perú

Inkia

China Three Gorges

Goldman Sachs

CBB Perú (formerly Cementos Bío Bío)

Work highlights

  • Advised Zest Capital on the design and set-up of tax efficient structures for their investment funds, to enable customers to have preferential tax treatment when making investments in different type of offshore product.
  • Provided tax advice to Air BP PBF del Perú (a subsidiary of Valero Energy Corporation) in connection with a successful refund of the input VAT and with the audit that was subsequently carried out by the Tax Administration in connection with said tax.
  • Successfully represented Empresa Agroindustrial Paramonga in the amparo proceeding which was begun with the aim of obtaining a Constitutional Court ruling on (i) the operation of the statute of limitations, given that the company had been litigating for almost 15 years, and (ii) the extinction of interest accrued past the time the authorities had to decide on the administrative claims submitted against the notices of assessment.

PricewaterhouseCoopers Peru

A hefty multidisciplinary team of lawyers, accountants and economists at PricewaterhouseCoopers Peru organises itself along sector lines and represents a comprehensive range of industries, from finance and private equity to industrial manufacturers. The legal team includes eight partners, each with a different area of focus: overall practice head Arturo Tuesta; office managing partner Orlando Marchesi, who is lead adviser to foreign multinationals; Gino Menchola, who specialises in tax consulting; and all-rounder Miguel Puga, are all key practice figures. The practice excels in cross-border transactions and tax structuring, advising a raft of Peru's most well-known companies.

Practice head(s):

Orlando Marchesi; Arturo Tuesta; Gino Menchola; Lourdes Chau; Miguel Puga

Work highlights

  • Advised a significant consumer goods company on the tax aspects of its acquisition of a former competitor.
  • Advised a Peruvian industrial company on the tax due diligence during its acquisition of an entity in the same sector.
  • Provided comprehensive advice on tax issues regarding the sale of equity on behalf of an international private equity company.

CMS Grau

CMS Grau shines for its expertise in the tax aspects of transactions, particularly in the mining, oil and gas, and energy sectors, where it acts for the likes of Southern Peaks Mining and ISA Interconexión Electrica. Clients benefit from the shared know-how of the firm's global CMS tax management team, while a niche area of expertise is environmental taxation. Practice head Rolando Cevasco and the nine-strong team also handles litigation, tax planning and audits for example. Senior associate Carlos Chirinos leads the office's important transfer pricing practice.

Practice head(s):

Rolando Cevasco

Key clients

ISA Interconexión Electrica

Derco Perú

Sentinel Perú

Fridays

Panoro Apurimac

Maxima internacional

Belltech

Lumni

Empresa Editorial El Comercio

MSA del Perú

Nikken

Work highlights

  • Advised ISA Interconexión Electrica on the purchase of Orazul Energy Group for $158.5m, part of the ISA Group’s expansion strategy resulting in a 73% participation in the energy transmission market in Peru.
  • Advising Derco Perú on the tax implications derived from the transfer of the business line, as well as the evaluation of the structure of the transaction based on the General Anti-Avoidance Rule (GAAR).
  • Advising Southern Peaks Mining (SPM) on its application for the VAT Early Recovery Regimen related to its investments in the Ariana Project, including negotiations on modifications to an investment agreement with ProInversion.

Gálvez & Dolorier Abogados

Gálvez & Dolorier Abogados is an established tax and labour boutique that has built an impressive client roster of leading international and domestic companies, drawn to the firm's specialist expertise. Notably, head of litigation and tax planning José Gálvez led the successful defence of DHL Express Peru in the Supreme Court concerning the statute of limitations, saving the client a mighty $12m in VAT.  He co-leads a team of ten full-time tax lawyers alongside advisory and transfer-pricing head, partner Silvia Muñoz-Salgado.

Practice head(s):

José Gálvez; Silvia Muñoz-Salgado

Testimonials

The lawyers are up-to-date in their knowledge, care about knowing our industry to give measures in accordance with the business (this is their differentiation from other firms, knowledge of our business). Their best qualities are to provide agile solutions and with a range of possibilities. José Gálvez is recommended.’

The specialisation of the tax team stands out.’

They have rapid understanding of the problem and give prompt attention.’

Key clients

Arca Continental – Lindley

Trafigura

Telefónica del Perú

Tecnofarma

Andina de Radiodifusion (ATV)

Corporación Cerámica Lima (Celima)

Panamerican Silver

New Transport

Termochilca

Gloria

Belcorp

América Movil (Claro)

Work highlights

  • Advised Arca Continental Lindley on legal and tax matters regarding its restructuring process.
  • Successfully defended DHL Express Peru before the Supreme Court regarding a matter related to VAT from the year 2001 and the correct application of the statute of limitations, saving the client tax of approximately $12m.
  • Successfully defended Telefónica del Perú during an inspection phase regarding digital services and thus income tax for the non-domiciled.

Gálvez, Risso, Zegarra & Asociados

Gálvez, Risso, Zegarra & Asociados is a well-resourced tax boutique that fields five partners supported by a heavyweight 20-strong associate bench. With the bulk of partners formerly at the 'Big Four' consulting networks, there is deep expertise and experience on offer across all aspects of tax work. Managing partner Ramón Gálvez focuses on both tax structuring and litigation; Carolina Risso has 23 years' experience in corporate and tax law; and Carlos Zegarra leads on litigation and international trade and customs. Karen Alegría and Christian Cáceres complete the partner line-up.

Practice head(s):

Ramón Gálvez; Carolina Risso; Carlos Zegarra

Testimonials

The confidence of being in the best hands in customs and tax matters makes this firm an unconditional one for my company. The expert handling of the subject, the hard and soft skills regarding what clients need to hear, and the speed in the attention makes them a unique offering. Definitely, other firms have tempted me but when it comes to results, there is no doubt that Galvez, Risso, Zegarra & Asociados are unmatched.’

Carlos Zegarra is an unconditional lawyer for me. I have been in three different companies and in all three he has advised me in an incredible way. In my in-house management, what I did is consolidate and expand the consultancies, to make him our main advisers. In the same way, Rony Arancibia and Alejandro Escudero are a great complement to the team.’

It is a multidisciplinary firm, with a very strong practice in the tax area. Its main partners are recognised as excellent professionals with extensive experience and recognition in the field, and the associates have a very good professional level. The attention they provide is highly personalised.’

They have deep knowledge in the tax area (which is what we specifically use), and extensive experience, which gives them perspective to approach problems and how to approach and solve them. They are very responsible and dedicated.’

‘I am very pleased since in a very short time they put together the necessary team to answer queries and being a boutique studio they are very personable.’

I work very closely with Ramón Galvez. I have him as a head lawyer, he takes a complete look at professional consultations, he is a person who becomes very close to the matter, generating trust immediately.’

The Galvez, Risso, Zegarra and Asociados team is multidisciplinary, which makes us calm in the different areas or topics to be discussed. We can talk about foreign trade, taxes, transfer prices and litigation and they understand it easily; in addition, their experience in the aeronautical sector is a strength.’

Christian Caceres and Carlos Zegarra have a personalised approach to their clients and in addition, their technical experience is indisputable.’

Key clients

Alicorp

LATAM Airlines

Gerdau (Síder Perú)

Aje Group

Avianca Perú

Devanlay (Lacoste)

Ransa

Niubiz

Transcorp

América Móvil

Panificadora Bimbo

Graña y Montero

Netafim

Work highlights

  • Representing a transport company before the tax authorities, SUNAT, which sought to determine if air cargo transportation activities qualify as exempt from the sales tax regime and whether inter-airline operations reduce sales tax recovery.
  • Representing an international client regarding an incorrect excise tax assessment, successfully persuading the Tax Court to fully revoke the Tax Administration assessment.
  • Assisting a multinational company to build and implement a technological tool that allows for managing tax information and tax inspection processes.

Miranda & Amado

Miranda & Amado handles all types of advisory, tax planning and transactional matters, as well as litigation before all levels of the courts and administrative bodies. Indicative of the calibre of expertise, head of practice Pablo Sotomayor is leading advice to Telefónica del Perú in a potentially leading case before the Tax Administration concerning a claim against a FITEL tax assessment for the years 2007 to 2014. While Sotomayor is the sole partner of the team, there is marked seniority at associate level, particularly in stand-out individual Luis Miguel Sánchez; the more junior Nicolás Valverde is also highlighted.

Practice head(s):

Pablo Sotomayor

Testimonials

The team is very professional. They have a lot of experience and excellent customer service.

Pablo Sotomayor is very responsive. He is directly involved and is very strong technically. Nicolás Valverde is an associate to follow.’

Strong points in the tax area are: knowledge of the company and our industry; easy access and contact; confidence; solid legal recommendations.’

Pablo Sotomayor knows the rules very well and how to apply them. His experience in the tax area generates a lot of confidence in us. Nicolas Valverde executes and puts into practice the agreed plans very efficiently.’

Solid and responsible.’

Its services are not only focused on solving specific questions that are asked but also on looking for alternatives that are outside the client’s spectrum, giving a more complete vision of the solutions.’

Key clients

SCOR Brasil Resseguros

The Vanguard International Group

Parque Arauco

Alicorp

Empresa Minera Los Quenuales

Siemens Perú

Transportadora de Gas del Perú (TGP)

Telefónica del Perú

Engie Energía del Perú

Tiendas Ripley / Banco Ripley

Prosegur

Minera Las Bambas

Arte Express

Work highlights

  • Representing Telefónica del Perú before the Tax Administration on a claim against a FITEL tax assessment for the years 2007 to 2014, a potentially landmark case.
  • Successfully represented Medic Ser before the Tax Court on a refund claim of real estate tax paid for the years 2012 to 2015 to the Local Government of Miraflores (LGM).
  • Providing tax advice to Bank of America, Citigroup, Credicorp and JP Morgan Securities in Banco de Crédito del Perú (BCP)’s $850m offering of subordinated fixed-to-fixed-rate notes due 2030 under its existing medium-term notes programme.

Estudio Olaechea

Advising on all aspects of contentious and non-contentious tax, Estudio Olaechea reports a busy year, advising on tax planning, double taxation agreements, cross-border partnership agreements, customs issues and disputes, among other matters. An effective partnership duo comprising Jorge Dávila and Carolina Rodríguez, particularly strong in corporate tax and customs matters respectively, lead half-a-dozen associates in representing an enviable client list including: Google, BlackRock and Mattel. Among current mandates the team is advising Netflix regarding potential new Peruvian legislation relating to VAT on services provided through digital platforms.

Practice head(s):

Jorge Davila; Carolina Rodriguez

Testimonials

They investigate all the scenarios that could be generated before a query, and keep the answers open. As an example, we have had tax consultations that have another legal effect and for this we are supported not only by the tax team but also by the corporate team that joins the consultation meetings.’

We need a multifunctional team that can handle the different requirements of our company, in the different legal, municipal, and fiscal spheres. Olaechea perfectly fulfills these requirements, so it compares favourably with the other firms.’

Martin Olaechea, who assists us directly, has vast experience on the laws, decrees, regulations, etc., of Peru, and if necessary from other countries, and has the necessary contacts and advice to support us in our daily operations.  Jorge Davila has complete knowledge of the tax legislation of Peru, and with this his advice in all tax matters he has become invaluable to our company.’

Key clients

Continental Towers

Michelin

Forest Stewardship Council

Hapag Lloyd

BlackRock

Alcatel-Lucent del Perú

Clorox

Jet Blue

Air Canada

Little Caesars

Ola & Montaña

Google

Top Rank

Bray Controls

Yoder Media

Enerjet

Inmobiliaria Regal

Imerys Chile – Minera Montparnas

Saint-Gobain

Tacama

SNC Lavalin

AT&T

Gol Linhas Aereas

ACS (a Xerox Company)

Aristocrat Technologies

National Oilwell Varco (NOV)

Viva Air

Mattel

Caterpillar Financial Services Corporation

Peruvian Andean Trout

Work highlights

  • Advised Desarrollos Terrestres Peru on the most tax-efficient legal structure to carry out their operations with ATM Towers in the country.
  • Advising Netflix in relation to a new tax issue in Peru which has not yet been regulated in the country, concerning the application of VAT on services provided through digital platforms.
  • Advised Google with regard to diverse consultations related to applicable taxation in the country.

Rebaza, Alcázar & De Las Casas

A compact but effective team at Rebaza, Alcázar & De Las Casas is particularly strong on advice relating to tax structures for M&A transactions and domestic and foreign investment in general. Contentious mandates are also undertaken, including administrative disputes before the tax authority and judicial courts. Camilo Maruy leads a team of four associates specialising in the field, including experienced seniors Víctor Valdez, who advises clients from the financial industry in particular; and the highly praised Pablo León. BTG Pactual and SMU Perú (Mayorsa) are among several recent client gains. Since publication, Valdez has been raised to the partnership and the practice has been further strengthened with the hire of experienced transacitonl tax partner César Luna Victoria from Rubio Leguía Normand - with effect from January and March 2022, respectively.

Practice head(s):

Camilo Maruy

Testimonials

The greatest virtue for me in this area is the exceptional knowledge of tax applicable to wealth management and family matters.’

Camilo Maruy and Victor Valdez are very talented. I highlight the team’s experience in complex transactions. They are very close to the customer. ‘

It is a highly qualified team that has a magnificent command of the subject. They are proactive and solve customer problems quickly and efficiently. The relationship between quality and fees is very good. ‘

Their high knowledge of the specific subject in question stands out. Associate Pablo León is one of the best professionals I have ever met.’

They are lawyers with a lot of knowledge in tax matters, very dedicated and available 24/7.’

Dedication is a stand out feature.’

Key clients

Brescia Group

Wiese Group

AC Capitales

Pesquera Cantabria (Kulisic Family)

Sigma

Bolsa de Productos de Chile

BTG Pactual

Entel Group

Grupo EOM

Bolsa de Valores de Lima (BVL)

Cavali ICVL

Interbank

Scotiabank

Acres Investment

Fit Capital (previously, Adcap Securities)

Sura

Crowdcredit

Grupo Migiva

Grupo Edifica

Banco GNB

COFIDE

Glencore

Camposol

SMU Perú (Mayorsa)

Work highlights

  • Advised Sura Asset Management on the tax audit procedure against the Peruvian Tax Administration regarding a remaining debt challenged by SUNAT and related to the sale of shares in an international transaction.
  • Advising Blanco Sociedad Administradora de Fondos de Inversión on the launch of a real estate investment public fund (FIRBI)
  • Advised Peru’s sole stock clearinghouse Cavali ICLV on the implementation of the common reporting standard which was implemented for the first time in Peru in August 2020

Rubio Leguía Normand

Rubio Leguía Normand has a focused and comprehensive practice, acting for mulitinationals and large domestic companies across the mining, energy, TMT, banking, and health and beauty industries in particular. Notably, the team has stand out expertise in the tax aspects of PPP projects. It boasts two specialist partners in Luz María Pedraza, who is strong on advisory work such as planning and reorgansiations; and transactional adviser César Luna Victoria. A support team of five includes counsel Gilberto Ramos and the 15-years-qualified Karen Temoche. Since publication, Luna Victoria has left the firm, with effect from March 2022.

Practice head(s):

Luz María Pedraza

Key clients

Metro de Lima Línea 2

Enel Green Power

Terna Plus

Newmont Mining

Termochilca

Anglo American Quellaveco

Credicorp

Ansaldo STS (sucursal del Perú)

GenRent del Perú

Work highlights

  • Advised Grupo Energía Bogotá (GEB) on the tax aspects of its acquisition of Dunas Energía )and subsidiary Electrodunas), launching GEB into the power distribution market of Peru.
  • Advised Enel Green Power on obtaining approval as a qualified company to benefit from the VAT early recovery regime with respect to its ‘Central Eólica Wayra I’ project.
  • AssistedCitybike Perú with tax planning to order to obtain the highest tax efficiency in the corporate reorganisation of the Marfina Group companies in Spain, Finland and Peru.

Cuatrecasas

A new entry to the ranking, Cuatrecasas is building a credible tax practice under the leadership Juan Pablo Porto, former director of the legal tax team at PricewaterhouseCoopers Peru. He brings over 15 years’ experience of advising at the highest level, his practice spanning cross-border transactional support, tax structuring and disputes. Other areas of focus for the group include tax optimisation procedures, audits and advanced VAT recovery. Porto leads two associates on advising a broad and expanding client list that includes Belcorp, W Capital and Viettel Perú.

Practice head(s):

Juan Pablo Porto

Key clients

Salog

Belcorp Sa (Peru branch)

CETCO

Shared-X Perú

Cannfarm Peru

Titan Contratistas Generales

C y J Constructores y Contratistas

Oceano Seafood

W Capital (Grupo Wiese)

Viettel Perú

Work highlights

  • Ongoing tax advisory to Salog, a logistic service provider to all public hospitals in Lima, including: reviewing its operations since 2012, a corporate reorganisation of the group and the tax effect and consequences of entering the reactivation loan programme secured by COFIDE.
  • Advising Belcorp on a review of its operations since 2012 for the purposes of advising on the anti-avoidance rule, and on the tax effects of a complex structural reorganisation that includes Belcorp’s branch in Peru.
  • Providing tax advice to CETCO on the group’s day-to-day issues, taking into account their position in several Latam jurisdictions.

De Bracamonte - Haaker - Castellares

De Bracamonte - Haaker - Castellares supports its core banking and finance practice with relevant tax capability, the main focus of the tax work being financial and corporate transactional support. However, there is a growing stand-alone practice at the firm undertaking both litigation and advisory mandates on behalf of companies and private clients. a case inpoint was the team's recent representation of Nyrstar International in a dispute with SUNAT. At the helm is Cristina Chang, a versatile tax lawyer who is growing in profile and leads a team of four associates.

Practice head(s):

Cristina Chang

Testimonials

The team is very dynamic and receptive; it quickly assimilates the issue raised and they have knowledge and excellent communication.

The level of knowledge of inter-group management stands out, as well as the rapid resolution of issues. Cristina Chang is recommended.

Key clients

Volcan Compañía Minera

Menorca Inversiones

CSalud

Scharff Logística Integrada

MC Inversiones Peru (Mitsubishi Group)

Merck

Agrofino Foods

Odebrecht

Southern Bridge Capital

Izipay

Work highlights

  • Represented Nyrstar Netherland Holdings and Nyrstar International in a tax litigation against SUNAT regarding cost certificates issued by SUNAT accrediting the cost of the shares issued by Nyrstar Coricancha and transferred to Great Panther Peru.
  • Advised Menorca Inversiones on the tax implications arising from its corporate spin-off.
  • Advised CSalud on the analysis of the rectification of VAT returns for the fiscal year 2015, and its possible consequences, in order for the company to be able to use the VAT paid for the acquisition of medical services before its merger with Clínicas Maison de Santé.

Dentons Peru

Dentons Peru has a broad offering, attracting an impressive array of high-profile domestic and international clients, such as Backus and Johnston, Total and Penguin Random House. Lorena Galvez has over 20 years' experience advising on tax planning, cross-border transactions and inbound/outbound investments, previously working in the US and at a leading Peruvian tax boutique. Notably she led advice to UK construction company Mace in respect of the tax aspects of its agreement with the Peruvian government to assist with rebuilding infrastructure damaged by the El Niño phenomena in 2017.

Practice head(s):

Lorena Galvez

Testimonials

The Dentons tax team specialises in providing practical and timely solutions to its clients through quick and easy-to-understand answers, even for non-specialists. They are tailored to the client’s needs and are highly accessible.

‘Friendliness, accessibility, punctuality, prompt response, and a practical approach. They do not get lost in theories or cumbersome explanations. They look for the solution that best suits the client’s situation.’

Key clients

Mace

Backus and Johnston

Total

Wenco

Megacentro

Lamor

Ecapital

Fresenius

Penguin Random House

Paz Centenario

Work highlights

  • Advised Mace -as a strategic partner of the UK’s DTI- on the negotiation and design of the most efficient tax structure (according to the terms of negotiation with the Peruvian State) for participation in the rebuilding of infrastructure in the northern parts of Peru affected by the El Niño phenomenon in 2017.
  • Advised a medical group on tax due diligence with regard to clinics that are identified as targets.
  • Ongoing advice to Megacentro in relation to tax planning, growth strategy and capital injection.    

DLA Piper Perú

DLA Piper Perú joins the ranking following a significant boost to its tax practice in March 2021 with the hire of new head of practice Erik Lind, formerly a partner at Estudio Echecopar member firm of Baker McKenzie International. He joins experienced principal associate Sheila Espinal (who had been leading the practice) and a small team of associates. Lind brings a broader skill base to the practice, which until now has focused on corporate support and compliance matters, and is expected to grow the advisory and litigious capability at the firm.

Practice head(s):

Erik Lind

Testimonials

This is a very good area of practice, particularly the team’s close working with the client, proactivity and knowledge.’

DLA Piper Peru strives for exceptional results, detail oriented without delaying time spent.’

Sheila Espinal is outstanding and knows how to really work in team endeavours.

Key clients

Oaktree Capital Management

ATC Sitios del Perú

Sociedad Agrícola Tres Cruces

Sura Asset Management

Tecsup

Grupo Basa

Inmobiliaria Habilita

Graneles del Perú

Intralot de Perú

Inverdesa (Bodytech)

Work highlights

  • Advised ATC Sitios del Perú, a wireless infrastructure company, on the tax aspects arising from its acquisition of 1089 telecom towers from Entel Peru and the structure of the post-transaction leasing agreement.
  • Advised Latin American pensions company Sura Asset Management, specialised in savings and investment, on all the tax aspects related to the acquisition of 129 real estate units (4357.92m² leasable office area) in Patio Panorama Business Centre located in Santiago de Surco, Lima.
  • Acted for Tecsup, a top-tier higher education tech institution in Peru, on a corporate restructuring of the group, including designing a strategy to simplify operations under a lower tax scheme.

Garrigues

Growing in profile, the team at Garrigues advises an impressive client roster of leading domestic and international companies, with stand-out strength in corporate and finance transactional support. It notably led tax advice to Heineken on its landmark entry into the Peruvian market, for example, work led by head of the practice Javier De La Vega, a seasoned tax lawyer who specialises in consultancy, structuring, compliance and due diligence. His team of eight associates includes principals Rosa Chevarría, a litigator, and Rafael Martinelli, who is particularly experienced in cross-border transactions.

Practice head(s):

Javier De La Vega

Testimonials

Excellent knowledge of complex tax issues, specifically related to financial and M&A issues. Rosa Chevarría stands out particularly for her commitment, quality of service and expertise.

Ability to work under pressure efficiently and without neglecting details, as well as the delivery of jobs/advice within the deadlines agreed with the client.’

The Garrigues tax team, in addition to having a high level of knowledge of the issues, is capable of proposing practical alternatives to complex situations that a company may go through. I also highlight the way they present their points in a firm, convincing and diplomatic way during the meetings. Garrigues stands out from other firms.’

Plus points are: specialised knowledge, pragmatic points of view and negotiation techniques. Qualities: empathy, availability. I highlight the participation of Javier de la Vega and Hernan Aquije.’

‘I would highlight their fast response to requests and clarity and quality of advice. Javier de la Vega and Armando Buendía stand out.’

Key clients

Camposol

Virú

Morgan Stanley

Green Gold Forestry Peru

ProInversion

Ampacet Spain Holding

Universidad Internacional de la Rioja (UNIR)

PPRO

Heineken

IHS Netherlands BR

Sumitomo Mitsui Banking Corporation (SMBC)

Carlyle Group

Prosegur

Compass CIM Latin America (CCLA)

Work highlights

  • Advising Heineken (over a period of two years) on the main tax considerations associated with its entry to the Peruvian brewery market, including substantial tax structuring and addressing pre-existing tax liabilities of local taxpayers with which Heineken was set to execute relevant agreements.
  • Advising Ampacet on defining the most tax-efficient structure (from a Peruvian perspective) for the group’s international corporate restructuring, and successfully representing the company before the Peruvian Tax Administration in the context of challenging tax audit proceedings, as well as obtaining a full cost certification on the Peruvian shares that were transferred as a result of the operation.
  • Advising the State’s private investment promotion agency, ProInversion, on the updating and drafting of tax-related clauses of the concession agreement for Lima’s Peripheral Ring Road (Anillo Vial Periférico), a $2bn highway project that aims to improve connections between several districts of the Lima Metropolitan Area.

Payet, Rey, Cauvi, Pérez Abogados

Payet, Rey, Cauvi, Pérez Abogados has a capable tax team under the leadership of Vanessa Watanabe, who is growing in expertise and market profile. The team excels in advising on the tax aspects of complex and cross-border transactions, the core area of focus of the practice, although judicial and administrative dispute work is also undertaken, such as the practice's recent representation of Scotiabank in judicial proceedings concerning a disputed VAT payment. Associates to mention include Ivy García-Pacheco and Lisset López, who both have broad business tax experience.

Practice head(s):

Vanessa Watanabe

Testimonials

Strong points are the working proximity with the client, and the quick response to the queries made.’

‘I think the ability to anticipate problems, review the entire case to see all the angles, are the strengths. Alfredo Chan, Lissette Lopez and Vanessa Chavarry stand out.

Highlights: the response time that allows you to make quick decisions; accuracy in the answers and recommendations; interrelation between its different areas in such a way that the client is informed how an opinion, for example of a corporate nature, influences the tax part. Compared with other firms, it is favourable.

The collaboration, the very good predisposition they have to help you with questions and the time of their responses are strengths. The lawyer I always consult with on the tax-side is Vanessa Watanabe.’

Key clients

Administradora Prime

Carlyle Group

Banco de Crédito del Perú

Scotiabank Perú

Savia Perú

Hortifrut

Kallpa Generation

Inversiones Centenario

ABB

Enfoca Sociedad

Work highlights

  • Advised InRetail Perú Corp on the acquisition of 100% of Makro Supermayorista, which operates a cash-and-carry wholesaler supplying food and non-food products to industry clients as well as individual customers through its 16 stores in Peru.
  • Advised Banco de Crédito del Perú, as issuer, in connection with the tax implications on the redemption of $850m of previous issued bonds.
  • Acted for Scotiabank on a constitutional defence suit (amparo) asking the judiciary to invalidate a Tax Court Resolution that confirms SUNAT’s resolution which assessed Scotiabank with a tax debt of $170m resulting from a supposed omission of a VAT payment.