Hernández & Cía offers large domestic and international clients ‘solid experience’ in the tax field, handling the full range of contentious and non-contentious matters. It is particularly active on tax issues pertaining to M&A deals, general advisory matters, compliance, litigation and cross-border tax planning. The team is co-led by the very experienced Luis Hernández Berenguel, along with Milagros Bustillos and Leonardo López. Berenguel is a huge name in the market and has previously assisted with the drafting of Peruvian tax legislation; Bustillos has considerable experience in representing clients in administrative proceedings before the National Superintendence of Customs and Tax Administration (SUNAT); and Lopez is the name to note for customs and international trade matters. Fernando Nunez is another key practitioner; he focuses on corporate and transactional tax, while Rodrigo Flores is recommended for international tax issues. Counsel Patricia Tamashiro is also active on key transactions and senior associate Julio Sáenz handles tax litigation.
Tax in Peru
Hernández & Cía
Practice head(s):
Luis Hernández; Milagros Bustillos; Leonardo López
Testimonials
‘The lawyers in charge of attending the company’s services have been involved with the company’s operational issues, in order to understand the business and prepare the appropriate responses regarding the observations made by the tax administration‘.
‘The solid experience they have in the tax field is evident‘.
‘The partner Luis Hernández has solid knowledge but also actively participates in the meetings and deepens understanding of the issues he works on‘.
‘The Hernández team is very solid, which allows them to provide us with adequate solutions to the queries we make‘.
‘Milagros Bustillos, who has been advising us for many years with a professional manner‘.
Key clients
Silver X Mining Corp
Elliot Management
Unión de Cervecerías Peruanas Backus & Johnston
Carlyle Investment Management
Sojitz Arcus Investment
Grupo Telefónica // Telefónica del Perú
Procter & Gamble
Perupetro
Instituto Peruano de Acción Empresarial (IPAE)
AB Inbev
Petrex
Interbank Group
Metrocolor
SES Satellite
Lumina Copper
Sacyr
Seven Seas Water
Los Portales
Fábrica de Cubiertos
Grupo El Comercio
Telecom Bolivia
Demega Desarrollo Inmobiliario
Servicios Turísticos Generales (SETOURS)
Condor Travel
Work highlights
- Acted as tax counsel to Sojitz Arcus Investment on its acquisition of the majority participation of its partner Grupo T-solar Global in two Peruvian solar energy project vehicles GTS Majes and GTS Repartición, which operate photovoltaic power generation plants with a capacity of 20MW each in Tacna and Arequipa (Peru).
- Advised Servicios Turísticos Generales (SETOURS) and Condor Travel on preparing and presenting impugnation proceedings and appeals at the administrative level against resolutions issued by the National Superintendence of Customs and Tax Administration – SUNAT.
- Provided tax advice to Unión de Cervecerías Peruanas Backus & Johnston on the implementation of a significant internal reorganization in Peru, which implied a series of transactions as the reverse downstream merger between Backus and Racetrack (shareholder of Backus), the distribution of accumulated earnings recorded because of the merger, and the obtaining of a loan for working capital purposes from a non-resident affiliate.
Philippi Prietocarrizosa Ferrero DU & Uria
With a strong regional presence, Philippi Prietocarrizosa Ferrero DU & Uria is well placed to handle international tax and trade matters for multinational companies. Veteran tax practitioner Walker Villanueva heads the practice and has considerable experience in national and international tax planning operations; he is also a professor at Pontificia Universidad Católica del Peru and has published books on Peruvian tax law. Dante Sanguinetti, who jointly leads the team, focuses on corporate and personal taxation, and corporate restructuring work; Carlos Moreano is a SUNAT alumnus and a key name for contentious tax issues; and Johana Timana was recently promoted to director and is well versed in tax issues pertaining to cross-border transactions. At the more junior end of the team, principal associates Milagros Pastor, Elizabeth Contreras and Alexa Adriazola are recommended.
Practice head(s):
Walker Villanueva; Dante Sanguinetti
Testimonials
‘The quality of service is unique, access to partners gives you peace of mind that problems or queries are being analysed in depth‘.
‘They have collaborated with us efficiently in all the projects that we have proposed‘.
‘They make you feel as a client that you are their priority, they are always willing to help‘.
‘Walker Villanueva is a professional with integrity, and extensive tax and corporate knowledge‘.
‘Their strengths are their knowledge of the regulations that apply to specific sectors, the various proposals they provide on how to deal with a problem‘.
‘They are always available and with fair rates‘.
‘The practice presents professionals with extensive knowledge in the specialised areas necessary for the operations of our company‘.
‘Members of staff are very accessible‘.
Key clients
Telefonica Del Perú
Compañía De Minas Buenaventura
Mabe
Comfer
Cornershop Perú
Zubale
Operadora Ecológica Del Titicaca
Consorcio Natividad De Chinchero
Monnet
América Móvil
Work highlights
- Advised Mabe Perú in relation to a dispute with the tax administration.
- Advised the Buenaventura Group on the sale of Yanacocha and the acquisition of Minera La Zanja from Newmont.
- Advising Telefonica del Perú on the tax aspects of the sale and disposal of its immovable properties, with a specific focus on the VAT impact.
Rodrigo, Elías & Medrano – Abogados
Fielding an impressive nine-partner team, Rodrigo, Elías & Medrano – Abogados stands out not only for its bench strength, but also due to the high-volume and high-profile mandates which it handles. On the transactional side, the practice is well known for tax matters relating to M&A transactions, equity and debt financings, restructurings and privatisations, among other areas; while on the contentious side, it draws on the expertise of firm's highly ranked disputes practice to represent clients in litigation. Alex Córdova co-heads the team and has notable experience in corporate tax, value added tax and extractive industries' taxation, as well as representing clients before the tax authority. Alex Morris, who jointly leads the team, is the key contact for wealth planning; dual-qualified in Spain and Peru, he is well versed in international fiscal transparency issues. Raúl Hidalgo handles the tax aspects of investment in infrastructure and administrative proceedings, while Tulio Tartarini deals with utilities taxation and Mariella de la Torre is recommended for tax issues in the mining and natural resources sector. Gustavo Lazo left the firm in September 2021.
Practice head(s):
Alex Córdova; Alex Morris
Testimonials
‘The difference compared with other firms is the reaction speed, accompanied by the seniority of the partners in charge of the matter‘.
‘They give a 360 ° look, not only on tax, but in other aspects of law‘.
‘They are always very attentive and willing to assist us on the issues that we bring‘.
‘Highly recommended‘.
Key clients
Minera Las Bambas
Minera Chinalco Perú
Grupo Falabella Perú
Telefónica del Perú
Tiendas por Departamento Ripley
Luz del Sur
Huawei del Perú
San Fernando
Compañía Minera Antamina
Southern Perú Copper Corporation (Peru branch)
Work highlights
- Assisted Southern Peru Copper Corporation in ligation before the Supreme Court related to a discussion regarding several assessments raised by the Peruvian Tax Authority to the 2003 Corporate Income Tax of fiscal year.
- Provided legal tax advice to Enfoca Servicios Logísticos on reviewing the tax consequences and most efficient manner to structure the operation of the multiple partial spin-off of Enfoca Discovery1 and Enfoca Discovery Parallel.
- Assisted Nexa Resources Cajamarquilla, a Peruvian company dedicated to producing and selling refined zinc, on an appeal before the Tax Court relating to a transfer pricing assessment on the sale transactions carried out with the related trader Votorantim.
Zuzunaga, Assereto & Zegarra Abogados
Pre-eminent tax law boutique Zuzunaga, Assereto & Zegarra Abogados advises clients on the taxation of international investments and the tax aspects of M&A, joint ventures and cross-border transactions; while on the contentious front, it handles litigation and tax arbitration procedures. Fernando Zuzunaga Del Pino focuses on corporate tax and tax defence; with fellow practice co-head Luciana Yanez focusing on international tax matters and tax planning for corporations and nigh-net-worth individuals. Juan José Assereto is experienced in the tax aspects of infrastructure projects, including those relating to financing, fiscal auditing and litigation, while Juan Carlos Zegarra focuses on extractive industries taxation among other areas. Lorgio Moreno represents clients before tax courts and the judiciary; and at the senior associate level, Tania Albarracín, Evelyn Yauri and Manuel Carrión are recommended.
Practice head(s):
Fernando Zuzunaga Del Pino; Juan José Assereto; Juan Carlos Zegarra; Lorgio Moreno; Luciana Yañez
Testimonials
‘It’s a niche studio. Very specialised in tax matters‘.
‘Fernando Zuzunaga is an excellent tax specialist‘.
Key clients
Enel Green Power Perú
Minera Barrick Misquichilca (formerly: Minera Boroo Misquichilca)
Fluor Group
Gas Natural de Lima y Callao (Cálidda)
Kallpa Generación
Minera MMG Las Bambas
Cumbres Andinas (Breca Group)
Fenix Power
Compañía de Minas Buenaventura
Alicorp
Corporation of the President of The Church of Jesus Christ of Latter-day Saints
Work highlights
- Advised Enel Group on the reorganisation of its renewable energy assets from Europe to Central and South America.
- Advised Minera Barrick Misquichilca on the tax aspects of its reorganisation with Boroo.
- Advised Minera Boroo Misquichilca on a work-for-taxes initiative.
Damma Legal Advisors
Damma Legal Advisors is a tax law boutique that services businesses and high-net-worth individuals on tax consultancy matters, auditing and restructuring, M&A-related tax issues and contentious matters, including litigation. Iván Chu is experienced in domestic and international tax matters and focuses on the banking and finance and corporate arenas, while Walther Belaunde is the name to note for corporate and mining tax issues, including reorganisations, business transfers, contractual matters and financing. José Chiarella, who speaks Spanish, English, Italian and Portuguese, is a key contact for private client work and acts for businesses on tax, corporate and civil issues; while Rocio Liu handles administrative and judicial tax litigation, as well as general advisory matters, with a focus on the natural resources, financial and telecoms sectors. Associate Eduardo Bedoya consults clients on tax compliance, inspections and litigation, among other areas. Since publication, the firm has hired Fernando Ocampo (formerly at Vodanovic Legal) as the director of its corporate projects and infrastructure practice - effective as of January 2023.
Practice head(s):
Walther Belaunde; Ivan Chu; Jose Chiarella; Rocio Liu
Testimonials
‘They search for innovative solutions following legal guidelines’.
‘Willingness to serve the client and a lot of professionalism‘.
‘The tax team is very good, highly specialised (especially in financial matters and in the oil & gas area) and provides a personalised service‘.
‘Rocío Liu is one of the best professionals in the field, she has great knowledge of very specialised tax issues (such as those related to financial issues and the energy and mining sectors)‘.
‘Rocío Liu is very even tempered and patient with clients, and she is very professional and accomplished in the assignments that are given to her‘.
‘This practice is unique for its technical knowledge and almost immediate attention capacity‘.
‘In the case of Walther Belaunde, he stands out for his experience and knowledge of the sector engineering and infrastructure sectors‘.
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
Work highlights
- Provided legal assistance to Sociedad Agricola Coscalla on the tax structuring of a joint venture to develop an important agricultural project with a strategic partner.
- Provided legal assistance on tax matters to Algeciras Inversiones on the structuring of a large real estate project to be developed with strategic partners in Lima, Peru.
- Providing tax and legal advisory services to Caoba Inmobiliaria in connection with the potential sale of a real estate project located in Lima, Peru.
Estudio Echecopar member firm of Baker McKenzie International
Estudio Echecopar member firm of Baker McKenzie International fields a team of ‘very outstanding professionals and resolves queries immediately and efficiently’. Leaning on its vast global network for support, the practice handles international tax matters with ease and is particularly experienced in tax-related corporate transactions, including M&A, and also reorganisations. It acts for a strong roster of multinational clients as well as smaller Peruvian companies, and in addition to its non-contentious corporate expertise, handles tax litigation proceedings before the Peruvian Tax Authorities. Rolando Ramirez-Gaston Horny heads the practice; with over 20 years’ experience in the field, he is well versed in wealth planning, tax audits and transactional issues. At associate level , principal associates Carla Peirano Castañeda, Cristina De La Piedra and Dora Ramos are recommended.
Practice head(s):
Rolando Ramírez-Gastón Horny
Testimonials
‘We have been using the services of the firm for years and it seems to us that their level of commitment and attention to the client is very high compared to other firms‘.
‘All the lawyers are very outstanding professionals and resolves our queries immediately and efficiently‘.
‘Very good tax team, reasonable deadlines for acquittal of queries, always available, and high level of knowledge on the matter‘.
‘Rolando Ramírez-Gastón Horny is an excellent lawyer specialising in tax law, always up to date with the issues, correct opinions, remarkable experience, and proposes innovative solutions‘.
‘They update us on legal changes in a preventive manner’.
‘Apart from the professionalism and knowledge of the law and our business, what stands out is the excellent attitude and empathy in serving us‘.
‘The Echecopar Study team is highly qualified‘.
‘They understand the sense of urgency of the business and provide us with information that allows us to make key decisions for the operation in Peru.’
Key clients
Herbalife
Derco
IBT
Grupo IF
Sodexo
Ajeper
FIBRA Larrainvial
Unilabs
Parque Arauco
Gloria
Kyndryl
Pontificia Universidad Católica del Perú
Minera Aurífera Retamas
Work highlights
- Advised IBM on the design and implementation of the corporate reorganisation of its subsidiaries in Peru and the tax effects of their global reorganisation to separate their infrastructure services business.
- Provided tax advice to Grupo Pochteca on its $20m acquisition of the Latin American business division of Ixom Operations Pty (Peru, Chile, Colombia, Brazil and Argentina).
- Provided local tax advice on the reorganisation and carve out of Olam’s business into four distinct operating groups – Olam Food Ingredients, Olam Global Agri, Olam International and Olam Technology and Business Services.
EY Peru
EY Peru fields ‘a really outstanding’ team with ‘transactional tax partners that have an individual reputation in the Peruvian market‘. The group has considerable domestic and international experience and advises clients on compliance, litigation, cross-border transactions and transfer pricing. The very large team is led by managing partner David De La Torre, who provides tax consultancy services, with a focus on corporate tax issues and who has particular experience of the oil and gas sector. Marcial Garcia is experienced in tax issues pertaining to the mining, retail, finance, insurance, manufacturing and utilities sectors; while Fernando Tori Vargas is recommended for corporate tax work, including M&A, post-merger integration work and divestments. Roberto Cores is a name to note for financial, banking and insurance tax issues, particularly relating to international taxes; and Humberto Astete provides tax consulting and planning services. Jorge Lizarraga moved to KPMG in August 2022.
Practice head(s):
David de la Torre
Testimonials
‘They have solid knowledge on M&A tax issues and the main characteristic is that it is a team that seeks fast and efficient solutions for the most complex problems that a transaction may have‘.
‘During the last year, the EY transactional team has stood out in the market for the quality of lawyers it has‘.
‘It is a comprehensive team with which cross-border transactions can be worked on in an efficient way and with the confidence that the client is in good hands‘.
‘The EY transactional team is differentiated by the speed and efficiency with which they work‘.
‘The lawyers are really outstanding and the transactional tax partners have an individual reputation in the Peruvian market‘.
‘Technically it is an outstanding team, its level of agility in responses to unforeseen situations never disappoints, its reports are impeccable, with excellent methodology, which makes them easily understandable for recipients from different Spanish-speaking countries’.
‘They have become highly appreciated collaborators and we would love it if EY could replicate this quality of service in the offices of its other geographies’.
‘For me, they set a quality standard that I look for advisors in other geographies to replicate‘.
Key clients
Ajeper
Anadarko Peru
Angloamerican Peru
Angloamerican Quellaveco
Banco de Crédito del Perú
Banco Pichincha
Exxon Mobil Corporation
Intercorp Management
Inversiones Centenario
IR Management
Laureate Education
Gloria
Minera Barrick Misquichilca
Nexa Resources Cajamarquilla
Nexa Resources Peru
Pacífico Compañía de Seguros y Reaseguros
Phoenix Tower International
Solgas
Supermercados Peruanos
Telefónica del Perú
Terpel Comercial del Perú
Union de Cervecerías Backus y Johnston
Vinci Highways
Volcan Compañía Minera
Work highlights
- Advised Marhnos Group on all the tax issues related with the PPP “COAR Centro”, a co-financed private initiative to build, operate and maintain three emblematic high performance schools.
- Advised Unacem on a reorganisation.
- Advised Saint-Gobain Abrasivos y Adhesivos Peru on the tax due diligence, negotiation and tax structuring for the acquisition of a Peruvian target.
Muñiz, Olaya, Meléndez, Castro, Ono & Herrera Abogados
Muñiz, Olaya, Meléndez, Castro, Ono & Herrera Abogados’ tax law practice handles the full gamut of tax matters, with a focus on litigation, planning, compliance, audits and M&A and financing-related tax issues. The team caters to high-net-worth individuals as well as large international and domestic businesses. Practice head Fernando Castro brings strong corporate experience to the team and is recommended for transactional matters; while Daniel Ono is a tax litigation expert experienced in a wide range of sectors – including automotive, industrial, pharmaceutical and consumer products. Jorge Otoya was recently promoted to principal partner and is well versed in cross-border transactions; while Frezzia Saavedra is a name to note for tax compliance matters. At the associate level, César Castillo and Cesar Angulo are recommended.
Practice head(s):
Fernando Castro
Testimonials
‘The positive points are the availability of the agenda for meetings/calls and quick responses to our e-mails‘.
‘Lawyers are always willing to give us support‘.
‘Jorge Otoya is a partner of our business, that is, an advisor who knows our “business”, knows our companies and our tax positions, and is always available to give us advice and recommendations with efficiency and objectivity‘.
‘The fact of having a firm and a lawyer that we trust brings us a lot of peace of mind in doing business in Peru‘.
Key clients
Cementos Bío
Inkia Energy
Corporación Lindley
Telefonica del Perú
Delosi
Pepsico
Honda del Perú
Interbank
Maersk
China Three Gorges
Colgate-Palmolive del Peru
Pfizer
Nestlé
Zest Capital
Work highlights
- Advising Telefonica del Peru on an amparo proceeding which was aimed at getting a ruling from the Constitutional Court in connection with the extinction of interest accrued past the time the authorities had to decide on the administrative claims, submitted against the notices of assessment.
- Advised Empresa Agroindustrial Paramonga on an amparo proceeding which ended up with the issuance of a precedent pursuant to which the Constitutional Court recognised that the application of the statute of limitations can only be suspended during the legal term set for the Tax Court to decide on appeals, but once that term expires, the limitation period can be computed again.
- Advised Valero Energy Corporation on the design of a strategy which allowed the client to recover overpaid regulatory taxes and get a precedent for the assessment of the tax for future years.
CMS Grau
The tax team at CMS Grau is most active on transactional mandates from the mining, oil and gas, and wider energy sectors. Practice head Rolando Cevasco has significant experience handling all aspects relating to corporate reorganisations and M&A, as well as wealth management and asset protection. Senior associate Carlos Chirinos specialises in transfer pricing, including acting for EDF Energy Chile on profitability planning among its intragroup operations, as well as advising on the analysis of cross-border company contracts. ‘Attentive‘ senior associate César Dávila leads on administrative and judicial litigation, while other work areas involve tax planning operations and various audits.
Practice head(s):
Testimonials
‘The advantage that the CMS Grau studio has is that it has known us for many years. You can get better at proposing new initiatives based on that knowledge.’
‘César Dávila is always attentive to attend to the issues that are required of the group.’
Key clients
ISA Interconexión Electrica
Derco Perú
Sentinel Perú
Fridays
Panoro Apurimac
Maxima Internacional
Belltech
Lumni
Empresa Editorial El Comercio
MSA del Perú (MSA Group)
Nikken (Mexican Group)
Globenatural Internacional
Indus
Sensient
Falabella Group (Saga Falabella, Open Plaza, Tottus, Tiendas de Mejoramiento del Hogar, among others)
Inmobiliaria Morada
Tupemesa
Auplata
Ubits Learning Solutions
Alomar Servicios Médicos
Emerson Electric Co
Coelvisac (Consorcio Eléctrico de Villacuri)
EDF
Inmobiliaria Pardo 200
Work highlights
- Advised EDF on transfer pricing matters and provided advice on the analysis of intercompany contracts from France to Peru.
- Advised Grupo El Comercio on the sale of all the shares of Orbis Ventures and its Ecuadorian subsidiary Orbisventures EC – operating companies of PagoEfectivo (payment gateway).
- Advised Tupemasa on the income tax audit of 2019 that involves more than four million contingencies for the company.
Gálvez & Dolorier Abogados
Boutique firm Gálvez & Dolorier Abogados ‘allows you to be one step ahead' during disputes and advisory work ranging from audits and share disposals, to potential income tax or VAT-related transgressions. Led by head of litigation José Galvez, who ‘has incredible numerical agility', the team has recently acted for telecommunications company América Móvil in nearly 50 cases before the Peruvian Tax Court concerning – among other issues – customs and the application of the Peru-Chile double-taxation treaty. Support comes from a large team of 12, with transfer-pricing specialist Silvia Muñoz-Salgado also possessing significant fiscal policy and private practice experience; Martín Mantilla is another key contact.
Practice head(s):
Testimonials
‘The team at Gálvez y Dolorier is always focused on meeting our tax advisory and consulting needs. We receive innovative guidance based on the new regulations and jurisprudence, talks and bulletins prepared by the firm. Their treatment and personalized attention is an important differential for the company.’
‘The lawyers of the Gálvez y Dolorier firm have very relevant specializations in this area. For example, partner Dr. José Gálvez is a person who, in addition to mastering the legal and tax regulations, has incredible numerical agility, which is difficult to find in a lawyer. With partner Dr. Martín Mantilla, who notably guides us in the management of taxes, communications and inspections of the tax administration and sometimes supports Dr. Silvia Muñoz when cases related to transfer prices are presented. In addition, the firm has a team of lawyers, some seniors and others with less seniority who are developing their line of career.’
‘The Gálvez & Dolorier firm has a very solid tax area that allows for good results in examination processes and litigation before the Tax Administration. In addition, they always send tax updates that allow clients to be aware of the latest developments.’
‘In the firm we mainly work with Dr. Silvia Muñoz. His experience in the tax field allows our arguments to always be solid; it also has a general vision of the issues, which allows you to be one step ahead and able to prevent any tax contingency.’
‘Very complete team. They gave perfect support in all areas where they were needed.’
‘Great technical knowledge. Quick and very accurate response.’
Key clients
Telefónica España / Telefónica (Spain)
Celima
América Móvil (Claro)
Belcorp
Puma Energy
Arca Continental – Lindley
Trafigura Tecnofarma
Telefónica del Perú
Statkraft
Andina de Radiodifusión (ATV)
Corporación Cerámica Lima (CELIMA)
Panamerican Silver – Shahuindo
Los Portales
Tecnasa
Work highlights
- Advised Telxius Telecom on a process to certify the cost basis corresponding to an indirect transfer of Peruvian shares.
- Advised América Móvil (Claro) on the defense of 50 administrative cases.
- Advised Belcorp on the analysis and defence regarding an objection from the Tax Authority of approximately US$15 million for the income effect alone.
Gálvez, Risso, Zegarra & Asociados
Clients appreciate the level of ‘very personalised attention‘ offered by the deep bench at tax litigation, corporate tax and wealth management specialists, Gálvez, Risso, Zegarra & Asociados. Managing partner Ramón Gálvez-Márquez and Carolina Risso-Montes are further recognised for their ‘impeccable conduct and great professionalism‘ on operational structuring, and corporate and commercial advisory matters, respectively. The five-strong senior group of lead partners is completed by Carlos Zegarra, who heads up the tax litigation and international trade and customs practices in conjunction with Karen Alegría and transactional added-value analyst, Christian Cáceres. Other work includes customs planning and foreign trade, often in relation to the agribusiness, aviation and pharmaceuticals sectors.
Practice head(s):
Ramón Gálvez-Márquez ; Carolina Risso-Montes; Carlos Zegarra; Christian Cáceres; Karen Alegría
Testimonials
‘They are a very strong team in tax matters, although they also have very good lawyers in other areas, so they are able to provide comprehensive advice. They have very solid theoretical knowledge, but they do not lose sight of the practical approach, which is very important for companies.’
‘We have always received careful and very personalized attention from all the lawyers of this firm with whom we have had contact. Ramón Gálvez and Carolina Risso have solid knowledge and a lot of experience, and they enjoy great recognition in our environment. Their impeccable conduct and great professionalism make them highly credible professionals, both in the private and public sectors.’
‘Tax issues contain aspects of very high specialisation. In-house lawyers need to read and sign all the writings that a firm such as Gálvez, Risso, Zegarra & Asociados (GRZ&A) projects to promote technical communication and eventually contribute with the client’s own knowledge. Yes, it compares favourably with teams from other firms. However, I would add that GRZ&A has better equipment than many or the integrity of them. Regarding Ramón Gálvez, he is to be commended for his great knowledge, exercise of great common sense and the integrity of his team members. It is compared with other firms adding to their tax knowledge, which these firms have, the knowledge of the procedural and civil areas that GRZ&A also dominates and satisfactorily intertwines with the tax knowledge, in the exercise of defending its clients.’
‘Compared with other firms adding to their tax knowledge, the knowledge of the procedural and civil areas that GRZ&A also masters and satisfactorily intertwines with the tax knowledge, in the exercise of the defense of its clients. The firm’s best quality is to involve the internal lawyer in the deliberations and the frank search for a way out in which we all buy into the strategy and tactics to be applied. They are outstanding: Carolina Risso Montes (partner), Ramón Gálvez Márquez (partner), Viviana Cossio Carrasco and Gabriel Espejo (associates).’
Key clients
Alicorp
Latam
Gerdau (Sider Perú)
América Móvil (Claro Perú)
Avianca Holding
Niubiz
Aje Group
Grupo Corpol
Netafim
Panificadora Bimbo
Ransa (Grupo Romero)
Miranda & Amado
The ‘very transparent‘ and ‘very agile' offering at Miranda & Amado has a particular niche in regulated industries – specifically, oil and gas, electricity and telecommunications. Practice head Pablo Sotomayor ‘has outstanding experience and knowledge' and specialises in all aspects of M&A transactions, restructurings and planning. His team is adept at advising on sophisticated tax structures, complex cross-border financings and litigation – including ongoing representation of BHP Billiton before SUNAT regarding tax assessment errors. A pool of associates including experienced figures Luis Miguel Sánchez and Nicolás Valverde complete the team, for whom other recent clients include Telefónica del Perú and Empress Royalty.
Practice head(s):
Testimonials
‘They are very proactive and come forward with suggestions before problems arise. They keep records of all cases and continually remind us to take steps that would otherwise cause us problems.’
‘We are happy with the work of the M&A tax area. They are always willing to assist us immediately.’
‘I would like to highlight the work of Eduardo Pedroza, who demonstrated his experience in tax matters and especially in the matters that he advises us.’
‘The entire process of tax consulting has been very transparent, discussed and very agile. They have taken my name to contact all the people related to the delivery of the information.’
‘Their kindness, the quick response to our doubts or questions… being committed to what is mine… being part of the solution to these issues.’
‘Excellent personal and professional treatment of the staff of the law firm, especially Pablo Sotomayor.’
‘Pablo Sotomayor has outstanding experience and knowledge of tax issues, with resolution of requested issues as soon as possible.’
Key clients
The Vanguard International Group
Teleatento del Perú
Alicorp
Statkraft del Perú
TC Latam
Transportadora de Gas del Perú (TGP)
Telefónica del Perú
Engie Energía del Perú
Ecopetrol
Prosegur
Energía Eólica
Work highlights
- Assisting TC Latin America Partners on the transfer of its participation in several Peruvian associative contracts (“asociaciones en participación”) that invested in Peruvian real estate projects.
- Assisted KNOC and Ecopetrol (as a leading party in the transaction) on the transfer of its 100% equity shares in Offshore International Group (OIG), the ultimate holding entity of SAVIA Peru and its other Peruvian subsidiaries, for $1bn.
- Representing BHP Billiton’s interests in ongoing tax litigation before the Peruvian Tax Administration (SUNAT) carried out by Compañía Minera Antapaccay and Compañía Minera Antamina, regarding tax assessments to the mining operation from 2001 to 2019.
Estudio Olaechea
Estudio Olaechea operates in Peruvian and international tax and customs circles, with advisory matters involving planning, double taxation and cross-border partnership agreements. Department head Jorge Dávila handles a broad range of transactional work, typically involving transfer pricing, M&A restructurings and financial investigations. With the September 2022 promotion of former senior associate Michael Morales to the partnership, the practice has expanded its senior bench and continues to build capacity; Morales’ broad practice encompasses tax consultancy, tax structures and planning, advisory on inbound international investment operations, tax audits, inspections by the Tax Administration, and proceedings before SUNAT and the Tax Court. The team also has a contentious angle to its practice, recently handling various cost recoveries and appeals challenging compliance-related rulings. Key associate Natali Huaylla‘s practice is centred on tax litigation, as well as income tax and international tax consultancy.
Practice head(s):
Testimonials
‘The area is excellent in what they do, they get to know your needs and your business, solving any doubt and helping to achieve what you need. They also take huge consideration of the risks that you may take.’
‘They know the area in which they work, they have a lot of experience and it shows that they are in constant training.’
Key clients
Deezer
Philadelphia Union
Paramount Pictures
Bitmex
Wageningen University and Research
Mediterranean Shipping Company
EFG Bank
Cisco
Chelsea FC
Standard Chartered Bank
Hahn Air
Johnson & Johnson Argentina
OLX
Work highlights
- Acting as FLS’s local counsel in connection with conducting due diligence on the target companies of Thyssenkrupp Industrial Solutions in Peru.
- Advising Link Capital Partners Administradora General de Fondos on the due diligence of the purchase of 13 companies of the Red Megacentro group, by the Link Investment Fund – Inmobiliario I.
- Advising Paramount Pictures in relation to the tax treatment of the income obtained in Peru by actors and staff of their technical team for the filming of the movie “Transformers: Rise of the Beasts” in the country.
PricewaterhouseCoopers Peru
PricewaterhouseCoopers Peru fields a multidisciplinary team, which encompasses lawyers, accountants and economists, and is headed by Orlando Marchesi, Arturo Tuesta, Gino Menchola, Lourdes Chau and Miguel Puga. The practice has a strong focus on corporate tax work and is well-versed in M&A-related tax issues; moreover, it stands out for offering advice on accounting and financial issues, alongside the tax aspects of deals. Tuesta acts for large domestic and international clients on transactions, restructuring and investments; while Machesi handles acquisitions and exit strategies, and reorganisations.
Practice head(s):
Orlando Marchesi; Arturo Tuesta; Gino Menchola; Lourdes Chau; Miguel Puga
Testimonials
‘They know the legislation thanks to their proven experience in different operations and transactions and generate confidence in their management of relevant legal processes such as corporate mergers‘.
‘They know the applicable legislation and regulation and having carried out several transactions, they have experience that generates peace of mind in the operation‘.
‘Expert team and quick response‘.
‘Arturo Tuesta is very accurate in his assessments and recommendations‘.
Rebaza, Alcázar & De Las Casas
Rebaza, Alcázar & De Las Casas offers ‘exceptionally good services', particularly for tax structures in M&A transactions and domestic or foreign investments. Practice head Camilo Maruy Nordlander also advises on corporate reorganisations and planning, and has experience litigating against SUNAT in contentious administrative disputes. Financial specialist Víctor Valdez, who made partner in January 2022, is praised as a ‘structured and conceptual lawyer, being practical and results-oriented'; while transactional expert César Luna Victoria joined from Rubio Leguía Normand in March 2022. The practice group’s recent growth has been reflected in various new client gains, including H.I.G. Capital, Asociación Peruana de Empresas de Seguros and Compartamos Financiera.
Practice head(s):
Testimonials
‘Víctor Valdez, as a tax partner, has been our right hand in making decisions with tax impact in Peru. Victor is a structured and conceptual lawyer, being practical and results-oriented. He is close to the client, available to deal with crises and emergencies, and is open to dealing with the different officials and bodies of the company. The direct advice of a partner adds a lot of value to the services of Rebaza, Alcázar & De las Casas.’
‘Rebaza, Alcázar y De las Casas has a tax team trained at the forefront of tax law and well disposed to satisfy the needs of clients. We have received exceptionally good services in relation to the tax treatment of foreign investment in Peru, from investment to liquidation.’
Key clients
H I G Capital
Entel Group
Wiese Group
Mayorsa
Edifica Group
Asociación Peruana de Empresas de Seguros (APESEG)
BNP Paribas Cardiff
Fondos Sura
Parque Eolico Marcona and Parque Eólico Tres Hermanas
Cavalli I C L V
Bolsa de Valores de Lima – BVL (Lima Stock Exchange)
Mambo Group
Camposol
Pesquera Cantabria
AC Capitales
Gildemeister
Termochilca
Asociación de Fondos Mutuos del Perú
Asociación Peruana de Factoring (APEFAC)
Blanco SAFI
El Dorado Investments
Profuturo AFP
EOM Group
Compartamos Financiera
Intertítulos
Procapitales
360 Asset Management
Interbank
Scotiabank
GNB
Acres Investment
Migiva Group
Soldex
Nordex Windpower
Mcann Ericson
Work highlights
- Advised H I G Capital on the purchase of a majority stake in Ransa Group (part of the Romero Group), one of Peru’s leading economic conglomerates, which is comprised of several companies engaged in 3PL (third party logistics) services.
- Counselling Mayorsa on a judicial tax proceeding, audit procedure and day-to-day management.
Cuatrecasas
Cuatrecasas continues to establish itself in the Peruvian taxation arena, with the practice’s direction being forged by the well-experienced Juan Pablo Porto, best known for his expertise in consultancy. The practice handles matters ranging from cross-border transactional support and domestic audits, to tax structuring and optimisation procedures. Clients include high-net-worth individuals, family offices, private equity funds and agrobusinesses, with an influx of roster gains over the past 12 months.
Practice head(s):
Key clients
ID Consultores
W Capital SAFI
A y F Wiese
SALOG
La Quinta Feria (Grupo La Quinta)
Cannfarm Peru / Shared X
Nexlot
Sanitas Peru
Sierra Metals
Grupo T y C
Banco BICE
Work highlights
- Advising ID Consultores on the tax optimisation of real estate investment funds through joint venture agreements and on business restructuring.
- Advising W Capital SAFI on the tax optimisation of real estate investment funds through joint venture agreements as well as on business restructuring.
- Advising AYF Wiese on its appeal before the Peruvian Tax Court.
De Bracamonte - Haaker - Castellares
Clients appreciate the ‘relationship of closeness and very positive trust’ found at De Bracamonte - Haaker - Castellares, where Cristina Chang heads a tax group of five associates supporting the firm’s core banking and finance offering. Its work typically consists of financial and corporate transactional support, with a growing litigation offering on behalf of companies and private clients. As such, recent cases include representing Sociedad Francesa de Beneficencia and Merck Peruan in disputes with SUNAT.
Practice head(s):
Testimonials
‘What I value most about the firm’s service is the commitment they show at each stage of the process. They explain things clearly and concisely and at the same time advise on related issues that we have not thought of. They go outside the original mandate to find opportunities for improvement. They always answer quickly and in a timely manner; access to our lawyer has been very wide and the service impeccable.’
‘They differ in not only being aware of the hourly charge, but also in solving the problem. We really feel that there is a concern for us instead of feeling like another client. It is a relationship of closeness and very positive trust.’
‘We work mainly with Cristina Chang; we are satisfied with her management and innovative recommendations for the businesses we carry out, the focus on results is the main driver for us.’
Key clients
Vita Pharma
Menorca Inversiones
Merck Group
CSalud
Odebrecht Peru Ingenieria & Construccion
MC Inversiones Peru (Mitsubishi Group, winners of the Quellaveco Project)
Volcan Compania Minera
Izipay
Procesos de Medios de Pago
Manpower
Work highlights
- Advising Procesos de Medios de Pago on compliance with the “benefit test” in operations with related parties.
- Advising MC Inversiones Peru (Mitsubishi Peru) on compliance with the obligations to identify and declare the company’s beneficial owner.
- Advising Menorca Inversiones on the tax aspects of the different alternatives for the development of a new real estate business.
Dentons Peru
Dentons Peru has seen a recent uptick in transfer pricing work, given that the Peruvian authorities are beginning to audit this area more rigorously. Practice head Lorena Galvez has over 20 years’ experience assisting clients with tax planning, cross-border transactions and inbound/outbound investments. Other recent advisory work includes fintech-related offshore business expansions for WeFi Technology Group, and for Amazon on all legal and regulatory matters regarding the potential establishment of a domestic business in Peru.
Practice head(s):
DLA Piper Perú
DLA Piper Perú‘s practice head Erik Lind ‘is a recognised and respected lawyer‘ in the sector, with his team further praised for its ‘results orientation and meeting of objectives‘. Lind advises on the tax aspects of multimillion-dollar corporate transactions, compliance reviews and tax obligations, as well offering advice to high-net-worth individuals and family-owned businesses, particularly in the financial, construction, farming and mining sectors. Support comes from senior associate Luis Miguel Sambuceti, particularly as regards planning and audits.
Practice head(s):
Testimonials
‘Since Erik Lind joined the firm, he has given the firm much more visibility. Erik is a recognised and respected lawyer in Peru.’
‘Basically, it’s trust. We have worked together for a few years and what makes the DLA practice unique is the focus on creating customer loyalty by meeting the objectives inside stipulated deadlines. The strength of the team lies in teamwork to achieve a common goal. It compares favourably with the practice of other firms that do not necessarily conduct the legal strategy in an integral manner. Another of the virtues is the adaptation to the new technologies in force in the national legal environment.’
‘The constancy and the presence of knowing that they are permanently available for what the client requires. Their best qualities are results orientation and meeting of objectives. In particular, Erik Lind’s team; he is highly efficient in meeting the requirements of our organization.’
Key clients
American Tower Corporation
British American Tobacco del Perú
Kallpa Generación
Sura Asset Management
Tecsup
Grupo Basa
Sociedad Agrícola Tres Cruces
Importaciones Hiraoka
La Tinka
Inverdesa (Bodytech)
Fundación Central
Euroamericana de Comercio y Finanzas
MUVA
Sociedad Agrícola Mochica
IPESA Group
Star Up (Star Perú)
Compass Latam High Yield Fondo de Inversión
Work highlights
- Advised La Tinka by performing a review of its main income and expense accounts in order to determine eventual contingencies of future reviews by the Tax Administration regarding the Income Tax returns for 2019 and 2020.
- Advised Constructora Cumbres on the acquisition of part of Constructores Interamericanos’ Andalucia Real Estate Project, a multi-family social housing megaproject located in Trujillo.
- Provided tax and legal advice to American Tower Corporation on the $9.4bn acquisition of 100% of the Telxius Towers package from the Telefonica Group.
Garrigues
A ‘specialised team' at Garrigues offers corporate and finance transactional support, with practice head Javier De La Vega singled out as ‘a clear and precise expert' on general tax consultancy, structuring and compliance matters. The team also benefits from its notably strong principal associate pair; Rosa Chevarría leads on the litigation side and is well experienced in administrative proceedings against tax assessments performed by the Peruvian authorities; while the ‘exceptional' Rafael Martinelli is singled out for his ‘personalised customer service’, often on cross-border work.
Practice head(s):
Testimonials
‘So far we have had great treatment and order with respect to the service provided by Garrigues, both in terms of delivery of information, queries, including the order for billing for each service.’
‘Javier de la Vega and Ana Sousa: both have worked impeccably, being at our disposal for all our tax and corporate questions.’
‘It is a very specialized team, clear in explaining matters, very methodical and orderly in case management. Javier de la Vega stands out as a clear and precise expert, who knows how to explain complex matters in a simple way.’
‘Among their strengths is the availability and agility in responses. In addition, in general, a fairly solid knowledge is noted. I would say that they compare favourably against some competitors and somewhat below competitors such as EY who are also able to provide an answer considering accounting aspects.’
‘José Francisco Meier seems to me to be a partner who stands out for his speed of attention, an aspect that I highly value. Javier de la Vega is also a partner who is quite agile and who provides answers that are simple to understand and apply.’
‘The level of knowledge of the regulations and their correct applicability is the greatest differential of the Garrigues firm. The level of involvement in the objectives of their clients.’
‘Rafael Martinelli is exceptional. I not only highlight his technical skills and knowledge of tax matters, but also his quality as a person. His way of serving the client is very personalized and he always seeks to provide practical solutions to his clients that allow him to operate properly in the market.’
‘Personalized customer service and mastery of tax law. Rafael Martinelli is an outstanding lawyer.’
‘They have a lot of knowledge of the taxation generated abroad. They are very detailed with the analyzes carried out and the supports. Likewise, their response time is immediate and very kind.’
Key clients
Banco de Crédito del Perú (BCP)
Mercado Libre Perú
Government of Peru (through ProInversion)
Murex
Seche Environnement
Tecnove
InnerWorkings
Virú
Agua Lima
Inka’s Berries
Payet, Rey, Cauvi, Pérez Abogados
The tax department at Payet, Rey, Cauvi, Pérez Abogados is closely aligned with the firm’s corporate offering. Vanessa Watanabe‘s team of ‘high-level professionals' provides consulting services, advice on special audit assignments and acts on contentious matters before the Peruvian Tax Court and Judiciary - usually for clients in the retail, mining, energy and finance sectors. Principal associate Lisset López specialises in wealth management consultancy along with digital and cryptocurrencies taxation; while senior associate Renzo Grández is appreciated for her ‘experience in the business'.
Practice head(s):
Testimonials
‘The strong point that the tax area of the Payet firm has is its vast knowledge in the agro-industrial export business, in the business part and in the part of the tax regulations that regulate our operations.’
‘Renzo Grandez: experience in the business industry, analytical, profile of seeking solutions to problems. Alonso Rey has vast experience in the industry, direct in giving messages to management.’
‘They are not only high-level professionals, but they are also our business partners. They are always by our side providing us with advice, comfort and helping us to measure the risks of operations.’
‘Vanessa Watanabe and Jose Antonio Payet are the partners in charge of the tax and corporate areas, respectively. Both provide us with fundamental legal support in our transactions, providing us with legal advice, but also helping us to identify risks, giving us comfort and balancing the pros and cons of making our business decisions. We feel that they always accompany us in all the steps of the transactions in which we work together, helping us to identify the main problems or risks to which we are exposed.’
Key clients
The Carlyle Group
InRetail Perú.
Hortifrut
ABB
Banco de Desarrollo del Perú (COFIDE)
Scotiabank Perú
Kallpa Generation
Savia
Administradora Prime
Expertia Travel
Nexa Resources Atacocha
Agricola Pampa Baja
Work highlights
- Advised InRetail Perú Corp and its Peruvian subsidiary Inretail Consumer (as issuer), in connection with the tax implications of two international bond issuances: i) $600m in 3.25% senior secured notes under Rule 144A/Reg.S of the US Securities Act (due in 2028); and ii) P$555m in 4.90% senior secured notes (due 2028), also under Rule 144A/Reg.S of the US Securities Act.
- Advised Colombian’s state entity Financiera de Desarrollo Nacional on the analysis of Peruvian issues regarding the sale of Interconexión Eléctrica (ISA), a Colombian company which has Peruvian subsidiaries in the electricity market; the mandate involved analysing the tax consequences of the indirect transfer of Peruvian shares – especially with respect to Andean Community Tax Treaty’s benefits (Decision 578) – and participating in the due diligence of the ten Peruvian subsidiaries of ISA.
- Assisted Citigroup, Credit Suisse, JP Morgan and Santander, as initial purchasers, on Peruvian tax matters related to the issuance of $380m in 3.5% secured senior notes (due 2028), carried out jointly by San Miguel Industrias PET and NG PET R&P Latin America, under Rule 144A/Reg.S.
Rubio Leguía Normand
Under the leadership of practice head Luz María Pedraza, the team at Rubio Leguía Normand offers a broad array of tax advice, including the reorganisation of companies, audits, procedures and planning. It acts for a client base featuring multinationals and large domestic outfits from the mining, energy, TMT and banking sectors, has particular expertise on PPP projects – a case in point being its handling of the tax aspects of the new Metro de Lima Line 2. Transactional adviser César Luna Victoria departed the firm in March 2022.
Practice head(s):
Testimonials
‘In particular, we have two lawyers with whom we feel very comfortable working: Gilberto Ramos and Carla Zelada. Gilberto has a very important analytical capacity in our cases, he always tries to look for plans B or C in certain situations that are better than the original. Carla, has an excellent memory, remembers the criteria used, and also has a very important relationship with the agencies that monitor us.’
Key clients
Terna Perú
Metro de Lima Línea 2
Sercosta