Tax in Peru
Hernández & Cía. Abogados
Market frontrunner Hernández & Cía. Abogados remains at the pinnacle of legal tax advice, its name partner - Luis Hernández Berenguel - long revered for his knowledge and expertise in the field. The firm consequently attracts a raft of leading companies seeking business-critical advisory and litigious representation, such as Telefónica del Perú, which the firm is advising on litigation against the SUNAT relating to income and value-add tax stretching back to 1998, with significant economic impact for both company and country. The 11-strong team includes: Milagros Bustillos, who is leading the advice to Telefónica alongside senior partner Hernández Berenguel; Leonardo López, who has over 25 years' experience in the sector; and Fernando Nuñez, previously a senior manager at EY Peru. At associate level, both Patricia Tamashiro and Roxana Terrones stand out for their experience in key matters. Moreover, the team has been further strengthened with the arrival of senior associate Julio Sáenz from Zuzunaga, Assereto & Zegarra Abogados in March 2020, and -since publication- hiring Rodrigo Flores -formerly at CMS Grau - as a partner in December 2020.
Practice head(s):
Luis Hernández Berenguel; Milagros Bustillos; Leonardo López; Fernando Nuñez
Key clients
Compañia de Minas Buenaventura
Grupo Telefónica / Telefónica del Peru
Perupetro
Procter & Gamble
Petramas
Petrex
Unión de Cervecerías Peruanas Backus y Johnston
Terminal Internacional del Sur (TISUR)
Interbank Group
Pesquera Diamante
Cencosud Peru
Graña y Montero
IPSOS
W Capital SAFI (Grupo Wiese)
Hermes Transportes Blindados
Instituto Peruano de Acción Empresarial
Metrocolor
Work highlights
- Tax consultancy advice to multiple companies -including Procter & Gamble, Perupetro, Unión de Cervecerías Peruanas Backus y Johnston, Metrocolor and Interbank Group- regarding tax planning, preventive reviews, tax audits and tax-related administrative and judicial proceeding, among other matters.
- Acting for Telefónica del Perú in various judicial proceedings and appeals against decisions of the tax authority (SUNAT), regarding income tax and value added tax for various years dating back to 1998, and amounting to extremely high value sums.
- Advising various companies -including Unión de Cervecerías Peruanas Backus y Johnston, Grupo Graña y Montero, Hermes Transportes Blindados and Perupetro- on tax anti-avoidance compliance
- Acted for W Capital SAFI on the tax aspects of its $30m acquisition of 100% of the shares of La Gloria Propiedades from private equity fund Enfoca SAFI.
- Representing a company in the oil and gas sector on judicial and adminsitrative proceedings challenging income tax decisions by SUNAT.
Philippi Prietocarrizosa Ferrero DU & Uria
Regional heavyweight Philippi Prietocarrizosa Ferrero DU & Uria is well placed for the tax management of cross-border transactions and general tax advisory for multinationals. Indeed, the firm acts for global management consultants McKinsey & Company in this regard, advising it on trans-Latin American deals. It fields one of the largest teams in the market, with 14 advisers led by tax specialists Walker Villanueva, who acts for a stream of leading domestic and regional companies; and Dante Sanguinetti, an expert on inbound investment by international companies. The practice's tax litigation offering is also in great demand; it is led by Carlos Moreano who advises on tax inspection strategies as well as handling judicial and administrative proceedings. Experienced associate Milagros Pastor stands out for her focus on strategic planning and transaction support.
Practice head(s):
Key clients
Uber
Breca Group
BHP Billiton World Exploration
Latam Airlines Peru
Urbanova
Comasa
O3b
McKinsey
Balich Worldwide Shows
Sky Airline
Capital Centre
Intradevco Industrial
Work highlights
- Advising Uber on establishng a new business line in Peru, including the tax consequences of ‘ubereats’, given that -uniquely- Uber does not have an office or permanent establishment in Peru.
- Ongoing advice to Grupo Breca on tax planning for its 20 companies across multiple sectors.
- Representing BHP Billiton in its tax litigation cases with the Peruvian Tax Authority, SUNAT, regarding BHP’s mining projects and exploration activities.
- Providing McKinsey & Company Perú with regular tax consultancy advice concering its cross-border transactions, whereby the company acts as both service provider and client.
- Advised Balich Worldwide Shows on the tax aspects of its work for the opening and closing ceremonies of the XVIII Pan-American Games And Sixth Parapan American Games held in Lima in 2019.
Rodrigo, Elías & Medrano – Abogados
The human resources at Rodrigo, Elías & Medrano – Abogados eclipses rivals, its line-up of ten partners unmatched in the market and backed by a formidable pool of associates. The team size is indicative of the breadth of the practice, which encompasses all corporate tax needs, including complex litigation, with added expertise in individual wealth management, an area led by practice co-head Alex Morris. The firm excels in the tax strategy and implications of big-ticket transactions and financings, this year closing the Peruvian aspects of Belmond's global sale of its businesses to Louis Vitton for $3.2bn, advice led by Jose Talledo. The very highly regarded Alex Córdova is fellow co-head of the practice, and it also includes tax luminary Humberto Medrano, who remains active, albeit with a limited practice.
Practice head(s):
Key clients
Cerro Verde
Minera Chinalco Peru
Luz del Sur
Belmond
I Squared Capital
Votorantim Metais Cajamarquilla
Huawei
San Fernando
Compañía Minera Antamina (JV BHP/Glencore/Teck/Mitsubishi)
Southern Peru
Work highlights
- Acting as local counsel to Belmond Group on the tax aspects of the sale of its companies to Louis Vuitton, for an aggregate amount of $3.2bn.
- Successfully represented San Fernando in a Supreme Court case against SUNAT regarding its exclusion from a refund of payments by ESSALUD (national health contributions and Extraordinary Solidarity Tax ).
- Acted for Goldman Sachs and JP Morgan Securities on the tax aspects of the $563m debt issuance for the refinancing the Metro Line 2 project.
- Defended Contilatin del Peru in a tax claim procedure before the SUNAT regarding transfer pricing.
- Advised Yangtze Optical Fiber and Cable Company (YOFC) on the tax aspects of its $411m financing agreement with the Peruvian government as part of a PPP to expand broadband services.
Zuzunaga, Assereto & Zegarra Abogados
Zuzunaga, Assereto & Zegarra Abogados is the largest and most established of the tax boutiques. It sits at the forefront of the legal tax market, with a truly deep offering encompassing all facets of tax advisory and contentious matters. It is regularly called upon by larger firms to handle the tax aspects of headline transactions, such as Electro Dunas Cayman Holdings' $210m sale of 100% of the shares of Dunas Energía to Grupo Energía de Bogotá. The firm enjoys a strong following among mining and electricity companies, counting Glencore Perú, Minsur and Kallpa Generación on its books. A heavyweight team of 20 lawyers includes six partners: Fernando Zuzunaga, an elite tax practitioner; Sergio Vega León and Juan José Assereto, who led on the Electro Dunas deal; Juan Carlos Zegarra, particularly for matters in the extractive industries; Lorgio Moreno, who brings over two decades' experience to the table; and dedicated specialist Luciana Yañez, who has built a broad corporate tax practice.
Practice head(s):
Juan José Assereto; Lorgio Moreno; Sergio Vega-León; Luciana Yañez; Juan Carlos Zegarra; Fernando Zuzunaga
Testimonials
‘Best features are their knowledge of options for tax structures and knowledge of the operation of the Tax Administration.’
‘They are tax experts, but can also assist with general corporate (company secretarial) advice in sale of shares transactions.’
‘Fantastic turnaround time, comprehensive advice. Recommend Luciana Yañez and Manuel Carrión.’
‘Zuzunaga, Assereto & Zegarra Abogados provides us with tax advisory services. The fact that it is a boutique makes its approach very focused on our tax advice needs.’
‘What makes their service unique is the quality and expertise of its partners, some of whom come from long-term service at the Peruvian tax authority, which is a plus.’
‘They are highly organised and meticulous in their analysis. One feels that there is a method behind what they do which transmits security for a job well done. They know the tax issues very well and present the strategy clearly, neatly and always on time.’
‘They are always available and there is always a person on the team with knowledge of the subject for a first response. They always meet the date offered to give a report or opinion and their treatment is impeccable. As a client, it gives me peace of mind to see that my lawyer is always calm and ready for a meeting, that he is always available, that he always meets deadlines.’
Key clients
Alicorp
Blue Water Advisors
Compañía de Minas Buenaventura
Compañía Minera Antamina
Consorcio Transmantaro (ISA Group)
Enel Generación Perú
Fénix Power Perú (Colbún Group)
Fluor Group
Gas Natural de Lima y Callao
Glencore Perú
Ingram Micro
Kallpa Generación
Minera Barrick Misquichilca
Minsur (Breca Group)
New Concept Mining y Lezaire Management Limited
Rio Tinto Minera Perú Limitada
Savia Perú
Stierlift Transportes (Ultramar Chile)
Work highlights
- Acting for Electro Dunas Cayman Holdings on the tax aspects of its $210m sale of Dunas Energía to Grupo Energía de Bogotá.
- Advised Fluor Group on EPC agreements with Anglo American and Chinalco for the Quellaveco and Toromocho projects, respectively, including the tax impact on the operations under said agreements.
- Advised Minera Barrick Misquichilca on the tax and corporate aspects of the reorganisation of Barrick Group.
- Acted for Enel Green Power Perú with regard to the Special Regime for IVA Early Recovery; and representing Enel Generación Perú in a judicial dispute against the SUNAT regarding corporate income tax.
- Advising Kallpa Generación on the planning of and application for a $24m (including interest) income tax rebate from the tax authority.
Damma Legal Advisors
Established in April 2019, tax boutique Damma Legal Advisors is already gaining traction in the market, largely due to shrewd lateral hires of practice heads from leading established firms. The latest is Rocio Liu, former head of the tax team at Miranda & Amado, a coup for the new practice that already boasts: Ivan Chu, former head of tax at Payet, Rey, Cauvi, Pérez Abogados; Walther Belaunde, who came from Santiváñez Abogados where he led the tax area; and Jose Chiarella, former head of tax at Garrigues and previously a tax partner at tier-one firm Rodrigo, Elías & Medrano – Abogados. The practice encompasses all facets of consultancy, auditing, restructuring, transactions and litigation, acting for companies and wealthy individuals.
Practice head(s):
Key clients
Joy Global (Peru)
Sacy Construccion Peru
Southern Peru Copper Corporation
Luz Del Sur
Lima Airport Partners
Ceramica San Lorenzo
Reyemsa
Enfoca Safi
Algeciras Inversiones
Continental Grain Company
Engie
Enel Distribución And Enel Generación (Enel Group)
Cementos Pacasmayo
Laboratorios Roche Farma
Hunt Oil Company Of Peru
Sucursal Del Perú
Intercorp Peru
Grupo Romero
Minera Aruntani
Chilles & Benson
Inkia Americas
Caoba Inmobiliaria
Work highlights
- Acted for Joy Global (Peru) during a SUNAT audit relating to operations in both Chile and Peru, successfully reducing the tax payable.
- Advised Southern Peru Copper Corporation on permanent establishment issues and the tax implications thereof, including efficient tax structures.
- Advised Algeciras Inversiones on the tax structuring of its $75m acquisition of four commercial malls situated in different regions of Peru.
- Ongoing advice to Enel Generación regarding an appeal filed against a tax assessment concerning supposedly omitted income tax and fines corresponding to fiscal year 2016.
Estudio Echecopar member firm of Baker McKenzie International
Estudio Echecopar member firm of Baker McKenzie International has considerable expertise in this area and is particularly strong in tax support for big ticket transactions, this year representing the State on two sovereign bond issues. It also excels in litigation, where recent highlights included reversing the Tax Court's approach to the law on tax deductions in labour contracts in a matter for Baker Hughes, while the firm's global platform makes it an ideal choice for international tax planning and transfer pricing services. Practice head Rolando Ramirez-Gaston Horny has 'deep knowledge that differentiates him from his competitors' and is supported by 'very aware' partner Erik Lind and six associates.
Practice head(s):
Testimonials
‘Their great strength is the ability to present different solutions to the problem posed with an economic and commercial vision; a clear focus on what the company needs. Also, their timely responses and clear explanation, which is easy to understand even in complex cases.’
‘It is one of the few firms that has expertise in private clients/equity structures and complements it very well with tax issues. Best feature is the dedication and availability of the partners.’
‘Very accurate and flexible advice. Specialised knowledge on the subject.’
‘Erik Lind is a lawyer who is very aware of the tax and business problems, so his advice is in line with our needs.’
‘We have used the firm on several occasions for situations relating to tax aspects of individuals, especially focused on people with very high assets. These types of profiles usually have complex legal structures abroad and the activity where they generate their wealth is very diversified. This requires a great deal of specialty to understand the steps to be followed by each client so that they meet their objectives, based on to the tax rules of the moment.’
‘The people in the firm have always shown great ability to analyse different customer situations and search for different options that achieve their goals. They have been very pragmatic lawyers and are very accessible.’
‘The team at Estudio Echecopar member firm of Baker McKenzie International handles matters very well and is superior to other law firms.’
‘Rolando Ramirez-Gaston Horny is a specialist tax lawyer with wide and deep knowledge that differentiates him from his competitors. The plus is that he responds very well to our needs, in a timely manner and with a high-quality service.’
Key clients
Herbalife
Derco
IBT
China Fishery Group (CFG)
Sodexo
AJE Group
FIBRA Larrainvial
Unilabs
Dupree
AGP
Jeunesse
Andina Trade
Willis Towers Watson
Logicalis Andina
Explora Hoteles
Smu-Mayorsa
Anglo American Quellaveco
Agro Vision
Apoyo Consultoria
Banco Santander
Work highlights
- Advised Parque Arauco (and some of its subsidiaries), on the tax aspects of its $120m purchase of 100% of the commercial business of Megaplaza shopping centre.
- Successfully represented Baker Hughes in the appeal of a decision by the Peruvian Tax Court regarding tax deductions at the conclusion of labour contracts.
- Acted for the Republic of Peru on the tax aspects on recent sovereign bond offerings of $3.1bn and $2.5bn.
- Advised a global investment bank on the tax structure of a new product.
EY Peru
Continuing to gain market share, EY Peru combines its significant cross-border resources with deep local knowledge to attract a raft of well-known multinationals as clients. Key figure and over-all head of tax, David De La Torre Delgado has over 25 years' experience and particular expertise in oil and gas matters. The six-strong international tax and transactions team, in turn, includes M&A tax specialist Fernando Tori Vargas and widely admired Edwin Sarmiento Lazo; and handles the full remit of tax advisory work, including tax planning and litigation, but is at its strongest in transactional matters. In this regard, it is well-versed in matters such as advising on tax cost reductions during the transaction cycle, efficient tax strategies and structures for acquisitions and identifying tax benefits connected to financing.
Practice head(s):
Key clients
Saint-Gobain Group
The Colony Group
The Carlyle Group
Okra Energy
Nexus Group
Odfjell Terminals Peru
Bank Of China
Expertia Travel
Inkia Energy
China Three Gorges Corporation
Geopark
UNE Asesores
Credicorp Group
MIQ Logistics – Noatum
Desarrolladora del Pacífico
Ontario Teachers Pension Fund
Work highlights
- Acted for an international manufacturer on the tax structure of its acquisition of a Peruvian manufacturing company.
- Advised an oil and gas company on the tax aspects of the structure and implementation of its internal reorganisation.
- Advised a company in the fishing sector on its internal restructuring and tax planning.
- Acted for a private equity fund on the tax aspects of its potential acquisition of one of the largest power and utilities entities in Peru.
Muñiz, Olaya, Meléndez, Castro, Ono & Herrera Abogados
Clients of Muñiz, Olaya, Meléndez, Castro, Ono & Herrera Abogados hold the lawyers' technical knowledge, 'holistic understanding’ and 'impeccable’ monitoring and due diligence work in high regard. With 18 lawyers including seven partners, the firm fields one of the largest teams in the market under the direction of Fernando Castro, who is currently leading advice to Telefónica del Perú on its colossal $1.5bn tax claim before the Supreme Court. Other landmark mandates during the year included the tax structure for client China Yangtze Power International's $3.6bn acquisition of Luz del Sur from Sempra Energy. Daniel Ono and Jorge Otoya are also key advisers.
Practice head(s):
Testimonials
‘They maintain a good technical knowledge and management of the business models that companies develop. One point of difference is that they are able to quickly recognise the tax impacts of different contracts and business models. The best feature is their technical knowledge.’
‘Their tax service coherently analyses each situation with a thorough and holistic understanding of each situation, being able to differentiate itself from other law firms, in my view. The monitoring and due diligence work is impeccable and there is always support, which makes it different.’
‘Jorge Otoya analyses each situation in a technical, precise way, and is fully able to understand all the issues involved, providing solutions that are always in strict compliance. Fernando Castro has a broad and complete vision of each situation, not getting stuck in micro decisions but sees the general and strategic framework.’
‘Very willing, committed people with a high professional level and charisma, especially Karin Orbezo.’
Key clients
Nissan Perú
Diageo Perú
Colgate-Palmolive
Pfizer
Tiendas Por Departamento Ripley
Abbott Peru
Valero Energy Group
Grunenthal Peruana
BASF Peruana
Work highlights
- Representing Telefónica del Perú in a $1.5bn tax claim before the Supreme Court.
- Advising Líder Gerencia y Construcción, a developer of real estate projects, in the design of a legal and tax structure of the first private residence for university students.
- Acted for Diageo Perú on the tax apsects of the merger between Diageo Peru and Diageo Tacna, particularly maintenance of the right to apply the tax benefits of the Special Tax Treatment Zone of Tacna.
- Advised China Yangtze Power International on tax planning relating to the structure and financing of its $3.6bn acquisition of Luz del Sur from Sempra Energy.
CMS Grau
CMS Grau has built an 'impeccable team’ comprised of multidisciplinary and focused tax lawyers, and which is particularly strong in transactional support in the mining, oil and gas and power sectors. Another distinguishing feature is the firm's recently introduced, in-house transfer pricing service, which has led to a sizeable increase in revenue for the department. The overall tax practice is led by Rolando Cevasco, noted for his experience in M&A support, corporate reorganisations, tax planning and audits. His team of six associates includes senior Carlos Chirinos who heads up the transfer pricing practice; however, fellow seniors Eduardo Arturo Rojas and Rodrigo Flores both left the firm, moving to ONTIER Peru (in August 2020), and Hernández & Cía. Abogados (in December 2020), respectively.
Practice head(s):
Testimonials
‘Eduardo Rojas and César Dávila have great knowledge, not only of tax but also financial and accounting in depth. They pose all possible scenarios and suggest the right path.’
‘They are far superior to the rest. They have an impeccable team and not only are they friendly and super-responsive, but they also have a deep understanding of the topics we tackle.’
‘I have dealt with Rolando Cevasco, Carlos Chirinos and Jose María Escalante and what I like about them is the excellent willingness to listen to anything I have to consult with them, whether big or small.’
Key clients
Clínica Maison de Santé
Clínica Santa Isabel
La Llave
Grupo Queirolo
Synthesia
China Railway
Dohwa
Artecola
Sierra Antapite
T-Rex
Grupo Sun Dreams
Vantage
Fábrica de Envases
Brexia Gold Plata
Grupo Falabella
Responsability America Latina
Southern Peaks Mining (SPM)
Development Specialists
Empresa Editora El Comercio
Tullow Oil
Work highlights
- Advising multiple companies on recently introduced transfer pricing regulations; all such work is undertaken within the firm.
- Acting for Southern Peaks Mining on its application for the VAT Early Recovery Regimen in connection to its investments in the Ariana mining project.
- Advised newspaper group Empresa Editora El Comercio on the tax structure required for the reorganisation of all the companies in the group.
Gálvez & Dolorier Abogados
Tax and labour specialists Gálvez & Dolorier Abogados handle a broad range of tax law, distinguished by its expertise in transfer pricing and more uniquely, the taxation of digital services, technical assistance, royalties, software and other e-commerce and IT-related operations. Four partners and nine associates advise a range of large taxpayers, from national and international corporates to wealthy individuals. José Gálvez heads the general tax and wealth management practice, with Silvia Muñoz-Salgado leading on transfer pricing matters. Martín Mantilla (tax controversy) is singled out by clients for his expertise, and Karina Arbulú (patrimonial planning) also recommended.
Practice head(s):
Testimonials
‘They are totally reliable lawyers who attend to matters in a very short time. Their strong points are experience and specialty in the subject.’
‘José Gálvez gets involved in the particularities of the business to express an opinion with perspective.’
‘Strengths and skills: ability to quickly answer queries aligned with the knowledge they have of our business; management of the law in general; permanent updates; ability to provide options. For all of the above reasons, it is superior to the other firms with which we work.’
‘The provide quick responses and valuble advice. They get involved in cases to give a range of solutions. Recommend José Gálvez and Martín Mantilla.’
Key clients
Arca Continental – Lindley
Angloamerican Quellaveco
Telefónica del Perú
Tecnofarma
Unique (Yanbal International)
Corporación Cerámica Lima – Celima
Termochilca
New Transport
Panamerican Silver
Los Portales
Andina de Radiodifusión
DHL
Consorcio Minero – Trafigura
Work highlights
- Acted for Consorcio Minero – in liquidation – in a transfer pricing process before the Tax Administration; estimated value $30million (fiscal year 2009).
- Successfully represented Latin American pharmacy company Tecnofarma in judicial litigation in the Court of Appeal against the Tax Authority regarding cost deductions related to free drug samples.
- Acting for Arca Continental Lindley in a challenge following a fiscal audit of intra-group services with transfer pricing implications.
Miranda & Amado
The tax practice at Miranda & Amado is particularly strong in tax issues facing regulated industries, attracting leading players from the telecoms, electricity, mining and oil and gas sectors - among others - as clients. Its nine-strong team is now reduced to one partner, the 'excellent’ and 'extremely reliable and technical’ Pablo Sotomayor, following the departure of former head of the practice and leading tax lawyer Rocío Liu to tax boutique Damma Legal Advisors in January 2020. It's a significant loss for the practice. On the associate bench, Luis Miguel Sánchez is a standout figure, with over 10 years' experience of international tax planning and compliance.
Practice head(s):
Testimonials
‘They are very quick to meet our requirements and very professional. They know their subject very well.’
‘Pablo Sotomayor is excellent. He is extremely reliable and technical.’
‘The team works very well, they are highly trained and provide an excellent service. They know our company and are always available to provide a timely response.’
‘Solid and responsible.’
‘They check our business regularly and warn us about complex matters, explaining the risks and vulnerabilities. They have a proactive attitude.’
Key clients
Hunt Oil Company of Peru
Grupo TDM Construcción
The Vanguard International Group
Parque Arauco
Alicorp
Empresa Minera Los Quenuales
Siemens Perú
Transportadora de Gas del Perú – TGP
Enel Group (Enel Distribución Perú, Enel Generación Perú, Enel Generación Piura, Enel Green Power)
Telefónica del Perú
Engie Energía del Perú
Tiendas Ripley/Banco Ripley
Cia. de Seguridad Prosegur
Minera Las Bambas
IC Power
Work highlights
- Representing Telefónica del Perú in a claim before the Tax Administration against an assessment of the FITEL (the State’s investment fund for telecommunications) tax for the years 2007 to 2014, amounting to $157m.
- Advising the Lima Stock Exchange on the proposed merger of the stock exchanges of Peru, Colombia and Chile.
- Acting for Medic Ser on a potential $480,000 tax refund (plus interest), following an assessment by the local government of Miraflores for an alleged real estate tax debt accrued between 2012 and 2014.
PricewaterhouseCoopers Peru
A hefty, multidisciplinary team of lawyers and accountants make PricewaterhouseCoopers Peru a dominant force in the Peruvian tax advisory market. The practice houses considerable expertise particularly veteran, Arturo Tuesta, who has over 25 years' experience in the field and is at the helm of the practice; Lourdes Chau, whose 2019 matters included successful in the Supreme Court; and Gino Menchola, who led advice to a bidder in a landmark transaction in the energy sector. the practice is undoubtedly increasing its profile, locally; however, former associate practice director Juan Pablo Porto moved to newly-established Cuatrecasas in September 2019.
Practice head(s):
Testimonials
‘They have a good, professional team.’
‘They know our business.’
Key clients
Viettel Peru Sac
Palmas Del Espino
Grupo Romero
Work highlights
- Acting for a client before the Tax Court regarding a mistaken declaration regarding income tax.
- Successfully represented a client in the food industry in the Supreme Court in a case relating to tax benefits in income tax.
- Acted for a signfiicant company in the energy sector on the tax planning and tax structure of its bid in a landmark deal in that sector; the target was eventually sold to another bidder.
Rebaza, Alcázar & De Las Casas
Rebaza, Alcázar & De Las Casas has a successful practice, supporting its tier-one corporate team in big ticket deals, but also earning a fair share of advisory and contentious work. An impressive and lengthy client list includes JP Morgan Private Bank, Entel Group and the Lima Stock Exchange, while others highlight the 'great dedication, service and easy access’ of the team. It is led by Camilo Maruy, whose strong track record in the sector includes considerable experience litigating against the tax authority before all instances up to the Supreme Court. Among a bench of five associates is Víctor Valdez, who 'stands out for his great technical ability. He is really what you call a specialist’.
Practice head(s):
Testimonials
‘Great dedication, service and easy access. Technically highly prepared and at the forefront of the latest trends and news on tax regulation.’
‘Víctor Valdez stands out for his great technical ability. He is really what you call a specialist.’
‘It has a very strong tax team. Víctor Valdez and Camilo Maruy know a lot about it. Their responses are on time and they are always ahead of what one may ask them by sending information constantly. Best points are their efficiency and commitment.’
Key clients
Brescia Group (Estratégica, Inversiones Breca and other subsidiaries)
Wiese Group (Negocios e Inmuebles, W Capital SAFI)
AC Capitales SAFI
Pesquera Cantabria (Kulisic Family)
Sigma SAFI
Bolsa de Productos de Chile
BTG Pactual
JP Morgan Private Bank
Entel Group
Grupo EOM
Bolsa de Valores de Lima – BVL (Lima Stock Exchange)
CAVALI
Interbank
Scotiabank
Acres Investment
Work highlights
- Acted for Grupo Wiese on the tax aspects of the $176m (approx) sale of its 50% equity stake in Inmuebles Panamericana, which holds numerous shopping centres throughout Lima and provinces, to Parque Arauco (Chile).
- Advised DP World Peru on the implementation of a new legal structure for its operations in Peru, including establishing new corporate vehicles.
- Advising a company in the financial services sector on proceedings against the Peruvian Tax Administration related to the fair market value of shares following a transaction.
Rubio Leguía Normand
The seasoned, standalone tax practice at Rubio Leguía Normand offers a comprehensive range of tax services, from transactional support, senior financings and tax planning, to administrative and judicial proceedings. Kelly Pérez successfully defended Huawei del Peru before the Peruvian Tax Court regarding the alleged withholding of income tax, in which the court considered the scope of 'digital services' for income tax purposes in Peru. Fellow partner César Luna Victoria brings 30 years' experience to the practice, focusing on the tax aspects of M&A, financings and cross-border transactions, while the practice can also call on the equally experienced, although somewhat less active, Luz María Pedraza.
Practice head(s):
Key clients
Metro de Lima Línea 2
Enel Green Power
Terna Plus
Newmont Mining Corporation
Termochilca
Anglo American Quellaveco
Credicorp
Ansaldo STS, Sucursal del Perú
GenRent del Perú
Work highlights
- Advised Grupo Energía Bogotá on the tax aspects of its acquisition of Dunas Energía and subsidiary Electrodunas.
- Acted for Enel Green Power on obtaining approval as a company qualified to benefit from the VAT Early Recovery Regime with respect to its Central Eólica Wayra I project.
- Successfully defended Huawei del Peru before the Peruvian Tax Court achieving a favourable resolution regarding the withholding of income tax for years 2013 and 2014, in which the court considered the scope of the concept of ‘digital services’ that qualifies as an activity that generates income tax in Peru.
De Bracamonte - Haaker - Castellares
De Bracamonte - Haaker - Castellares is distinguished for its 'level of precision’, 'accessibility’ and 'teamwork’. Head of practice Cristina Chang is cultivating a successful practice that largely supports the firm's corporate, finance and bankruptcy work, but also handles a growing range of standalone matters. Among the team's three associates is experienced Raúl Aguinaga, who is particularly skilled in designing tax structures. MC Inversiones Peru (Mitsubishi Group) and Odebrecht are recent client gains by the practice.
Practice head(s):
Testimonials
‘The strength of the firm is the comprehensive and effective advice. Unlike other law firms, their lawyers not only have extensive knowledge and experience in the legal issues, but they also have extensive accounting and financial knowledge.’
‘The firm has a high degree of commitment to its clients and an adequate response time for queries, characteristics that make De Bracamonte – Haaker – Castellares different to its competitors.’
‘The tax team at De Bracamonte – Haaker – Castellares, led by Cristina Chang and including Nora Lucar, has knowledge of tax regulations and accounting, is successful and also affordable to the client.’
‘They stand out for their level of precision in the tax council, the level of accessibility (hands on) and for their teamwork.’
Key clients
Menorca Inversiones
Merck Peruana
Volcan Compañía Minera
Scharff
Agrofino Foods
Gracco
Global Health Care Solutions Perú
Hoteles Estelar
Tecnogrúas Perú
Southern Bridge Capital
Consorcio OXI
Vita Pharma
Keyfarm
MC Inversiones Peru (Mitsubishi Group)
Odebrecht
Work highlights
- Representing Nyrstar Netherland Holdings and Nyrstar International (former shareholders of Nyrstar Coricancha) in tax litigation against the SUNAT regarding the cost certificates issued by SUNAT that accredited the cost of 100% of the shares issued by Nyrstar Coricancha (and transferred to Great Panther Perú) despite capital reductions and share cancellations that rendered its criteria incorrect.
- Representing Volcan Compañía Minera in tax proceedings before the Judiciary related to the determination of its income tax for fiscal year 2014
Gálvez, Risso, Zegarra & Asociados
Clients at tax boutique Gálvez, Risso, Zegarra & Asociados repeatedly applaud the availability, attention and personalised service provided by the 16-strong specialist team. The firm is particularly in demand for contentious advice at administrative and judicial level, and has niche expertise in the airline sector, acting for industry giants LATAM and Avianca Perú. The expanding practice saw two partners made up in January 2020: Karen Alegría and Christian Chávez. They join practice co-heads Ramón Gálvez, Carolina Risso and Carlos Zegarra, who focus on international taxation, transactional tax matters, and customs and international trade matters, respectively.
Practice head(s):
Testimonials
‘The strong point of the firm is the senior involvement in the affairs of our company, having direct access to the partners in relevant matters.’
‘Good attention to customer needs.’
‘They are a close team, easily accessible and with solid knowledge. They have a deep understanding of the cases.’
‘I dealt with Ramón Gálvez and Carolina Risso, who have a deep knowledge and know-how to adapt well to what the client needs, challenging them when necessary. They look for different strategies for each case, not staying with the easiest. Their personal treatment is excellent.’
‘Availability, attention to detail and involvement.’
‘Our company is attended by Karen Alegría who’s strong points are the direct treatment and involvement in each request, the attention to detail and above all, availability.’
‘It is a great team and knowlegde about airlines. The main strength is strategy management and focus on the client.’
‘Carlos Zegarra is honest, proactive and a leader in tax. He has built our trust.’
Key clients
Alicorp
LATAM
Gerdau (Sider Perú)
Aje Group
Avianca Perú
Devanlay (Lacoste)
Ransa
Nexa Resouces
Visanet
Virú
América Móvil
Panificadora Bimbo
Work highlights
- Acting for LATAM in proceedings before the tax authorities regarding VAT payable for the year 2013, which seeks to determine if air cargo transportation activities qualify as exempt from the sales tax regime and whether inter-airline operations reduce sales tax recovery.
- Advised Alicorp on a transfer pricing matter relating to a SUNAT audit of the value of raw materials acquired from a related trade company domiciled in Uruguay.
Garrigues
Garrigues 'has a good team that is highly regarded by the market'. Led by Javier De La Vega, who is praised for his technical knowledge and availability, its typical work comprises tax planning for large-scale M&A, corporate reorganisations and restructuring, financings and capital markets matters. Two departures in 2019 involved key members of the team, however: former co-head of the practice Jose Chiarella moved to new boutique Damma Legal Advisors; and principal associate Luis Valle to Arbe Abogados, where he has taken partnership to build the tax practice there. The Garrigues team still benefits from experienced principal associates Rosa Chevarría and Rafael Martinelli, while two hires at associate level during 2019 included Ana Sousa from ONTIER Peru.
Practice head(s):
Testimonials
‘They have the technical knowledge and the ability to convey it. They are very favorable compared with other offices.’
‘Javier De La Vega is recommended for his technical knowledge and his availability to serve us.’
‘Garrigues has a good team that is highly regarded by the market.’
‘Rosa Chevarría is an excellent person, super-prepared, very analytical. We are very satisfied with her work.’
Key clients
Red Eléctrica Internacional – REI
Camposol
Virú
Ibérica de Mantenimiento (Peru)
CenturyLink Perú
Bank of America
Green Gold Forestry Perú
Grupo Intercorp
Intermediate Capital Group
Lukoil
Metro de Lima Linea 2
MediaPro
Torres Unidas
Universidad de la Rioja
Veolia
Work highlights
- Advised Red Eléctrica Internacional on the relevant tax matters of its $205m acquisition of a 372km transmission line concessionaire in Northeast Peru from Bow Power/Cobra, including the special tax regime governing the concession agreements.
Estudio Olaechea
Estudio Olaechea has a well-resourced team focused on the full spectrum of tax matters. It attracts a strong following among international companies, assisting Google, AT&T and BlackRock, to name a few, navigate evolving Peruvian tax law. Experienced practitioner Jorge Dávila leads on corporate support, transfer pricing and litigation matters, while fellow partner Carolina Rodríguez is a specialist in customs-related issues. Sectoral strengths include air and maritime transportation, telecoms, financial services, gaming technology and education. Associate Natali Huaylla is recommended for both litigation and consultancy.
Practice head(s):
Testimonials
‘Estudio Olaechea has a team of professionals in all the areas in which our company requires advice. It is compared to the strong teams of other renowned firms in Peru and other countries, both in South America and in the rest of the world.’
‘The knowledge in the different areas of tax can be attributed to Jorge Dávila and the complete team.’
Key clients
Continental Towers
Michelin
Forest Stewardship Council
Hapag Lloyd
BlackRock
Alcatel-Lucent del Perú
Clorox
Jet Blue
Air Canada
Little Caesars
Ola & Montaña
Top Rank
Bray Controls
Yoder Media
Enerjet
Saint-Gobain
AT&T
Work highlights
- Advising Desarrollos Terrestres Peru (a member of the Continental Towers Corporation Group) on tax structures regarding its operations with ATM Towers in Peru.
- Acted for Tecnología de Materiales (TDM) in an auditing process, including representation in claims before the SUNAT, successfully obtaining sanction reductions.
Payet, Rey, Cauvi, Pérez Abogados
Payet, Rey, Cauvi, Pérez Abogados has 'extensive knowledge’ and its lawyers are 'solid, efficient and practical in their advice’. Vanessa Watanabe leads a team of capable associates among whom Ivy García-Pacheco, Lisset López and Renzo Grández are notably active in key matters. The group's primary focus is corporate and finance transactions, where the team provides tax advice on some of the country's largest deals. However, the team also advises on some significant general advisory and litigation matters: in a case in point, Watanabe is leading advice to Scotiabank in its judicial procedure against SUNAT regarding an assessed debt of $170m related to alleged VAT non-payments.
Practice head(s):
Testimonials
‘The lawyers inspire confidence and have extensive knowledge in general and in municipal tax matters. Other plus points are commitment to the client, dedication to commissioned issues, transparency in the information and handling of the cases.’
‘Recommend Vanessa Watanabe (partner) and Renzo Grández (associate): commitment with which the cases in charge are dealt with; attentive, either in person, by phone or by email; responsible and compliant with deadlines; knowledgeable of the client’s business; able to bring in other specialties if necessary. They give us confidence and security in handling our matters.’
‘With Payet, Rey, Cauvi, Pérez Abogados we have worked on tax legal issues, issues related to free competition and also spaces related to obligations of public companies. The firm undoubtedly compares favourably with other law firms given the in-depth knowledge it has in each subject as well as contributing to the search for solutions to complex situations.’
‘Personally, I trust a lot in the knowledge and interpretation of different regulations of the team at Payet, Rey, Cauvi, Pérez Abogados. They are solid, efficient and practical in their advice.’
‘The firm compared favourably to others, the answers are always correct and above all they respond in a timely manner.’
‘The answers are always clear and precise and most importantly, when it is required. Renzo Grández is recommended.’
‘They provide fast answers, especially Vanessa Watanabe and Ivy García-Pacheco.’
Key clients
Administradora Prime
The Carlyle Group
Banco de Crédito del Perú
Scotiabank Perú
Savia Perú
Hortifrut
Kallpa Generation
Inversiones Centenario
ABB
Enfoca Sociedad Administradora De Fondos De Inversión
Work highlights
- Advised The Carlyle Group on the tax aspects of its acquisition of amusement parks in Peru, Colombia and Chile.
- Acting for Scotiabank in its judicial procedure challenging a Tax Administration resolution which assessed that the bank owed $170m relating to the alleged omission of VAT payments.