Tax in Spain
Baker McKenzie provides ‘a high level of service’ and has ‘strong technical skills as well as finding the best solution for its clients’. Key areas for the firm include transactional tax planning, global reorganisations and tax litigation. The ‘creative and available’ Rodrigo Ogea, who is a specialist in cross-border investments, and Bruno Dominguez, who ‘merits recognition as a star in the Spanish tax market’, are the practice heads. They can call on the experience of tax audit and litigation expert Maria Antonia Azpeitia, who has ‘a strong and deep knowledge of the law’, and Luis Briones, who has expertise in M&A tax work. The department advised Thai company Minor Hotel Group on tax matters relating to its acquisition of a 38.2% stake in the Spanish company NH Hotel Group, and assisted Torreal with the acquisition of a 70.6% stake in Aernnova Aerospace. Raúl Salas left the firm for Roca Junyent in 2018.
Cuatrecasas focuses on corporate, private and litigation tax matters. Alicia de Carlos leads the multi-disciplinary team, which includes cross-border and M&A specialist Alejandro Escoda and Carlos Ferrer, who is particularly experienced in restructurings and the banking sector. The firm is advising Corporación Financiera Alba on tax issues relating to the acquisition, with CVC Partners, of 20% of Gas Natural Fenosa from Repsol. In another recent highlight, the department is assisting Acciona Energía with the sale of Acciona Termosolar, the indirect owner of five thermosolar plants in Extremadura and Andalusia. Other key clients include Barceló Corporación Empresarial, Grupo Pegasus and Bain Capital.
Working primarily for multinationals, J&A Garrigues SLP specialises in transactional tax issues. Practice head Eduardo Abad has expertise in the taxation and regulation of financial entities, as well as accounting law. His team includes restructuring and litigation expert Ricardo Gómez. The firm is advising Blackstone on tax matters arising from its joint venture with Banco Santander for the acquisition of the real estate business of Banco Popular. The department is also assisting CaixaBank with its deal to transfer 80% of its real estate business to Lone Star. Other key clients include Zurich Insurance, Carrefour and Vodafone.
The ‘international and local knowledge’ of Uría Menéndez gives the firm the ability to provide ‘a robust and global analysis’, particularly in the area of transactional advice and litigation. The ‘team of specialists emphasises client relationships’ and is led by expert in corporate tax law Rafael Fuster. His group includes the ‘outstanding’ Víctor Viana, who has ‘very deep knowledge of taxes in Spain as well as in general in Europe’ and ‘a level of commitment, prudence and availability that makes him a great adviser’. Also recommended are experienced tax practitioner David López Pombo and senior associate Roberto Medrano. The firm is advising Banco Santander on tax issues relating to the twofold capital market transaction concerning the acquisition of Banco Popular. In another highlight, the department is assisting Cinépolis Group with the Spanish tax law aspects of a syndicated credit agreement subject to New York law. Other clients include Alcoa, Telefónica and UBS.
Allen & Overy
Cross-border transactions specialist Allen & Overy is experienced in tax issues relating to the setting up and structuring of investment funds. The practice is led by international tax structuring expert Adolfo Zunzunegui, who has expertise in acting for financial institutions and insurance companies on international tax affairs. The team advised Banco Santander, BBVA and CaixaBank on the tax issues relating to financing provided to Forestalia Renovables for the construction and development of nine wind farms in Aragon. The firm also assisted Signal with matters arising from the €37.5m financing for the acquisition and refurbishment of a hotel in Ibiza.
Ashurst LLP's cross-border and cross-discipline practice has particular expertise in corporate transactional tax issues and disputes. International and European business law specialist Eduardo Gracia heads the practice and advises on tax matters relating to project finance, M&A and real estate. His team is acting for ICG on the tax aspects arising from the structuring of its real estate investment in Spain, namely the purchase and lease-back of six hypermarkets formerly owned by Eroski. In another highlight, the firm is assisting Castellana Properties Socimi, a major owner of retail assets in Spain, with tax matters relating to the acquisition of the Habaneras shopping centre.
Clifford Chance specialises in tax issues relating to investments and is known for its tax expertise in the corporate and real estate sectors. Transactional expert Pablo Serrano de Haro leads the practice, which also includes experienced council Roberto Grau, who is active in capital markets and finance. In recent highlights, the firm advised BBVA on the sale of 80% of its real estate business in Spain, and assisted Europcar Groupe, a France-based rent-a-car company, with the complex cross-border acquisition of Spanish company Goldcar from Luxembourg private equity firm Investindustrial. Other key clients include Santander, Autonomy and Sareb.
Freshfields Bruckhaus Deringer
Freshfields Bruckhaus Deringer focuses on tax issues relating to M&A and the practice is active in providing regulatory capital advice to financial institutions. Silvia Paternain leads the team and specialises in corporate cross-border transactions. Also notable is counsel Bosco Montejo, who is particularly experienced in tax matters arising from real estate transactions and group restructurings.
Specialising in cross-border transactional work, Latham & Watkins LLP’s practice is led by Jordi Domínguez, who is particularly experienced in complex M&A-related tax matters. The team also includes counsel Iván Rabanillo, who is a multi-jurisdictional tax expert. The firm advised private equity sponsor Värde Partners on the acquisition of an additional 49% stake in Spanish bank and credit card operator WiZink. In another recent highlight, the department represented Morgan Stanley International, JP Morgan Securities, Bankia and Banco Santander in tax issues relating to the issuance of €475m of senior secured notes. Other key clients include IFM Investors, UBS and Omnicom.
The multi-disciplinary team at Linklaters covers the full spectrum of tax matters, with a particular expertise in transactional work. The firm combines ‘a knowledge of the market and tax authorities’ with an ability ‘to understand the problems, analyse the different alternatives and provide operational solutions’. Javier García-Pita leads the practice and specialises in structuring complex financial products and corporate transactions. He can call on experienced counsel Alejandro Meca, whose areas of expertise include tax matters relating to cross-border M&A and litigation. The team is advising Cerberus, a US-based private equity firm, on the acquisition of Project Marina, and is assisting Ardian with its investment in two leading groups in the frozen bakery sector in Spain. Other key clients include Apollo, OHL and Qualitas.
Gómez-Acebo & Pombo is experienced in transactional, planning and tax litigation issues. The firm is active in contentious matters before the regional and national tax authorities, as well as national and supreme courts. The multi-disciplinary team is led by Enrique Ortega, whose expertise includes M&A tax issues. His team is representing FC Barcelona before the Spanish and other tax authorities, as part of a global tax audit, in relation to several ongoing tax controversies. In other highlights, the firm advised Japanese chemical manufacturing company Kaneka Corporation on the tax structuring of its acquisition of the Spanish company AB-Biotics, and acted for Santander in an appeal before the High Court of Justice of Madrid, in a tax litigation process involving Madrid real estate taxes.
Herbert Smith Freehills LLP
Herbert Smith Freehills LLP has particular expertise in corporate and business-related tax matters, including domestic and international tax planning. The team is led by counsel Marta Esteban, who focuses on the tax aspects of acquisition structuring, transactions and financing, and Nicolás Martín, who is a specialist in M&A and private equity tax. The firm advised Magnum Capital Partners on the tax implications relating to its acquisition of Indiba through a competitive auction process, and assisted HIG Capital with tax issues arising from the sale of Tres60 Servicios Audiovisuales to Media Producciones. Other key clients include Deutsche Bank, Carlyle Group and AEW Europe.
Pérez-Llorca has cross-border experience in tax matters arising from international transactions, and also represents clients in interactions with the Spanish tax authorities. Tax legislation expert Clara Jiménez leads the team and focuses on litigation and tax audits. M&A and real estate specialist Norma Peña i Bagés is head of the firm’s Barcelona practice. Also notable is tax litigation expert José Suárez, who was promoted to partner in 2018. The firm advised Banco Santander on the structuring of the transfer of Banco Popular’s 49% stake in WiZink to Värde and the acquisition of WiZink’s Banking Business. In another highlight, the department is assisting Adigital and its members with a legislative matter relating to the proposal of a directive on the taxation of digital services, made by the European Commission.
RCD has a strong track record in planning, private wealth management and corporate taxation. The firm has particular experience in the areas of transfer pricing and initial coin offerings. Founding partner José María Durán, Jorge Sarró, whose expertise includes inspections, collection and management of tax, and expert in the Spanish tax system Diego Artacho, who is a former tax inspector at the Superior Corps of State Tax Inspectors, are the practice heads.
Recommended for its ‘availability, dedication, knowledge and trust’, CMS Albiñana y Suárez de Lezo advises Spanish and foreign multinationals on a range of direct and indirect taxation issues. The ‘well-prepared’ team is ‘particularly strong in the key area of tax litigation’. Leading the practice is the ‘outstanding’ Diego de Miguel, who has ‘a solid knowledge of the entire tax system, expertise in tax litigation and quickly identifies important points’. The firm is advising Acciona on tax matters arising from the sale of its shipping company, and is assisting Savills with the tax implications of its acquisition of Aguirre Newman, in order to form a market leading real estate consultancy.
DLA Piper LLP specialises in advising multinational companies on tax restructurings and reorganisations, as well as providing M&A tax advice. Tax investigation and litigation expert Carlos Rodríguez leads the practice and his areas of focus include transactions, project finance and international securities. The firm is advising Atlantia on tax issues relating to its takeover bid launched for 100% of the shares of Abertis Infraestructuras. In another highlight, the team is assisting Nextera with its request for a corporate income tax refund. Other key clients include Abbott, Grupo Jorge and Laureate International Universities.
GTA Villamagna Abogados is known for its ‘long-term planning and anticipation of the activities of the tax authorities’ combined with ‘a great capacity to analyse various tax issues from multiple sides, especially the corporate perspective’. The team has ‘broad experience’ and is led by expert tax litigator Felipe Alonso, who stands out for his ‘professionalism, excellence and knowledge of the sector’, and Jaime Ena, who focuses on tax relating to restructuring matters, tax planning and corporate reorganisations.
Hogan Lovells International LLP has ‘wide experience and deep understanding of tax law’. The firm focuses on structuring asset financing schemes, M&A and real estate tax, and international tax planning. Miguel Angel Sánchez leads the practice and has ‘a strong knowledge of tax regulations’. Also notable in the team is the ‘professional, accurate and prompt’ senior associate Patricia Sánchez, who has ‘exceptional qualities as a legal adviser and excels in her work’. The department advised CNP Partners on tax issues relating to the acquisition of a majority holding in InsurTech iSalud, and assisted Allianz with tax aspects relating to the company’s acquisition of Multiasistencia. Other clients include Banco de Sabadell, Qualitas Equity and Sura Asset Management.
The ‘well-organised, efficient and flexible’ Roca Junyent ‘stands out for its adaptability, very high technical level in tax matters and international expertise’. The firm is active in a range of tax advice and litigation, particularly in cross-border issues. The ‘excellent’ Jordi Guarch leads the practice; he ‘understands the area and is very focused on reaching the client’s goal’. The team has ‘great technical ability’ and includes the ‘professional, available and resolute’ Blanca Usón Vegas. Strengthening the group is ‘top tax attorney’ Raúl Salas; his ‘knowledge of the tax laws of other countries makes him a creative thinker and ideal partner to solve cross-border tax problems’. Salas, together with associates Elena Ferrer-Sama, who has ‘a deep knowledge of corporate reorganisations’, and Pilar Vacas, who combines ‘technical ability with pragmatism’, were new arrivals from Baker McKenzie in 2018. The department advised Telepizza on the tax aspects of its alliance with Pizza Hut, and assisted Palex Medical with tax issues relating to three M&A transactions.
As well as experience in a range of non-contentious tax matters, Andersen Tax & Legal has expertise in tax litigation, notably in verification, management and inspection procedures carried out by the Tax Administration. María Olleros focuses on tax planning services to business groups and their shareholders. She leads the practice with specialist in international taxation Javier Vinuesa, who joined form Gómez-Acebo & Pombo in 2018. Further strengthening the team are tax specialists Jose Manuel Pumar, who joined from Auren in 2018, and Tomás Rivero, who arrived from Sanguino y Asociados Abogados, also in 2018. The firm is advising Grupo Alimentario Citrus on issues relating to the restructuring of the shareholder structure as well as on tax audit issues.
Araoz & Rueda is experienced in a range of domestic and cross-border tax issues, as well as legislation. Leading the team is Javier Prieto, whose specialities include tax advice arising from national and international M&A transactions. The firm is advising Esendex on the tax matters relating to the acquisition of its Spanish subsidiaries, and is assisting Atalante with the tax aspects of its acquisition of a majority stake in Goiko Grill. Other key clients include Axactor Spain, Sareb and Black Toro Capital.
The ‘very accessible team’ at Dentons has ‘a keen eye for detail and the capacity to work under pressure’. The practice is particularly active in advising insurance companies on warranty and indemnity policies and various related tax issues. ‘Fantastic’ corporate and M&A tax specialist José Ramón Vizcaino leads the team and focuses on direct and indirect taxation.
Eversheds Sutherland Nicea specialises in contentious, corporate and real estate taxation, as well as tax matters arising from M&A. The firm also has expertise in cross-border issues in the sector. Enrique López de Ceballos, who is focused on transactional tax advice, restructurings and wealth planning, and expert in real estate, corporate and contentious tax Antonio Cuéllar Prats are the practice heads. Key clients include Rockspring Property Investment Managers, Tyco Group and Citygrove Leisure.
King & Wood Mallesons
‘A pleasure to work with’, King & Wood Mallesons is ‘very strong in all tax matters related to M&A, corporate reorganisations, private equity and litigation’. The firm specialises in the tax aspects of M&A and is also active in the sports sector. Financial tax expert Alberto Ruano leads the practice and has ‘deep knowledge of tax law in Spain, as well as the client’s business, and is always available’. The team is advising Irea Corporate Finance on tax structuring and implementation relating to its merger with the real estate service provider Colliers International Group. In another highlight, the department is assisting Globe Invest with tax structuring pertaining to the acquisition of Tauro Real Estate.
Ramón y Cajal Abogados has experience in advising businesses and individuals on a range of tax matters, including indirect tax and transactions. The team also works closely with the firm’s M&A and private equity departments in related tax issues. Luis Rodriguez-Ramos is a key name in the practice and specialises in tax relating to M&A, finance and real estate investments.
Simmons & Simmons is active in cross-border transactions, particularly asset management and investment fund taxation. The firm’s tax team focuses on financial services sector clients, as well as real estate financing deals. Practice head Juan Sosa Pons-Sorolla is experienced in international tax planning, M&A and property taxation, for clients that include Henderson Global Investors, Morgan Stanley and BBVA.
Ventura Garcés & López-Ibor
The standalone tax practice at Ventura Garcés & López-Ibor has expertise in tax planning and related strategies; it acts for Spanish companies expanding abroad as well as foreign companies establishing a presence in Spain. Cross-border M&A tax specialist Jordi Vilalta leads the team with Lourdes Pérez-Luque, who is particularly experienced in advising on corporate income tax and VAT.
Watson Farley & Williams LLP
Watson Farley & Williams LLP focuses on tax issues arising from the renewable energy, transportation, real estate and industrial engineering sectors. Luis Soto leads the team and is experienced in advising clients on local and international tax matters concerning M&A transactions. The practice advised Avolon on the review of the leasing agreement tax clauses for two Airbus A320 aircraft leased to Iberia Líneas Aéreas de España, and assisted BNP Paribas with tax issues relating to the financing facility for the Spanish highway A-4 Road. Other clients include Bankia, Banco Santander and Grupotec.