Tax in Uruguay

Ferrere

Focused and dedicated to the client‘, Ferrere‘s tax team is one of the leaders in the market, where it provides a comprehensive service covering every aspect of tax law. Multinationals and some of the country’s leading domestic companies instruct the team on their tax structuring, as well as in tax litigation; a notable recent example saw Uber looking to the firm for advice on the structuring of its operations and compliance with tax regulations, as well as litigation concerning non-resident income tax and VAT. Practice head Gianni Gutiérrez is a renowned figure in the market, fully dedicated to tax, with expertise ranging from structuring the tax aspects of M&A to personal wealth planning. Isabel Laventure is also a dedicated tax partner, involved in the most complex issues, both contentious and advisory. Rising star senior associate Marcelo Marchetti departed in January 2021, but at the same level, María Laura Caffera is a tax specialist, noted for her expertise in tax and customs. Counsel Isabel Hounie is also highly regarded.

Practice head(s):

Gianni Gutiérrez

Testimonials

Extremely competent and up to date on tax and any other areas of law required for a comprehensive response.

Great sense of urgency and practical point of view.’

Responsiveness: it is a team of professionals that is always available to solve customer problems. The partners are always involved, ensuring quality of responses. Versatility: it is a team that has expertise in the most varied areas of tax practice, from corporate advice to the tax structuring of high net-worth individuals.

Very expeditious, very competent, a team of professionals.

Gianni Gutierrez and María Laura Caffera have responded immediately to all the needs of the company, much predisposition.

The Ferrere team has a vast experience of years in relation to our company. We feel understood in our needs, and we feel a strong personal and corporate interest in providing prompt, timely and reasonable solutions. They try to find ways that favor the client and are clear and emphatic to discourage lines of action that the client may consider interesting but are not.

We trust Ferrere a lot. Its greatest value is the prestige and image of the company. The size of the organisation allows us to consult not only the tax aspect but also those that are related and can influence our tax strategy.

It also has a remarkable team of people in different areas, such as Isabel Hounie, whose knowledge of accounting, taxation and related laws is incredible.

Key clients

Uber

Isusa

DirecTV

JPMorgan Chase

Suzlon Wind Energy

Archer Daniels Midland

Hidrovias do Brasil

IBM

Pluspetrol

Milicic

Colgate Palmolive

Syngenta

UBS

Nestlé

Work highlights

  • Acted for Hidrovias do Brasil in all matters of Uruguayan law related to the company’s IPO in Bovespa.
  • Represented Uber in a court challenge of decrees issued in 2017 establishing the obligation for offshore transport mediation platforms to pay non-resident income tax and VAT in Uruguay.
  • Advised Argentinean construction company Milicic on the structuring of its agreements with UPM for earthwork and grading for the new pulp mill project.

Guyer & Regules

Guyer & Regules‘ sizeable tax team is comprised of both lawyers and accountants and acts for a plethora of significant companies with interests in Uruguay, as well as government bodies. Juan Manuel Albacete, lauded by one client as ‘a benchmark in the field and an excellent professional‘, leads the practice and assists with both consultancy and litigation. He is a go-to tax professional for major banks and financial institutions, including BBVA, Goldman Sachs and Citibank, as well as other industry heavyweights. Associate Gastón Lapaz is a tax disputes specialist and assists Albacete with all major tax matters, with the finance and food sectors being particularly active in 2020. Noted associate Marcelo Marchetti further strengthened the team’s bench when he arrived from Ferrere in January 2021.

Practice head(s):

Juan Manuel Albacete

Testimonials

Professionalism and availability. Juan Manuel Albacete stands out.

I’d highlight the professionalism in which they work. Also, the training they have is very important.

It is worth highlighting the joint work that this area does with specialists from other areas, which allows for an excellent final result. The area has excellent professionals.

It is a team of excellent professional level. They always provide comprehensive advice covering all aspects. They also stand out for their great availability.

Juan Manuel Albacete is a benchmark in the field and an excellent professional. He has extensive knowledge of the subject and a great deal of experience, which is evident in the extremely valuable advice he gives us. He offers his experience and knowledge to provide practical and appropriate solutions to the problems that arise and having his support is of great value to his clients.

Gastón Lapaz is an excellent professional with extensive knowledge and a lot of practical experience as well as a great availability to provide advice and assistance in time to collaborate with the client’s needs. He is always ready to give answers to the questions raised and gives us very valuable advice for the interests of the company.

I mainly highlight the knowledge of the business and the fact of being permanently updated, which allows identifying risks and opportunities.

A very professional and dedicated team. We especially value the contributions of Juan Manuel Albacete.

Key clients

Citibank

Itaú Bank

Goldman Sachs

Barclays Capital

BNP Paribas Securities

JP Morgan Securities

BBVA

Julius Baer

Heritage

Montes del Plata

Petrobras

Mercado Libre

Total

Emirates

Corporación América

Louis Dreyfus Company

Bunge Agritrade

Cargill

Unilever

Philip Morris

VRG Linhas Aéreas

Tyco

Corporación Vial

Asociación de Bancos

Cabify

Work highlights

  • Advised Citigroup Global Markets, HSBC Securities and Itau BBA USA Securities as the underwriters in every tax matter regarding the Republic of Uruguay’s global bond and UPI bond issuances.
  • Acted for Upostal Group in all tax matters related to its acquisition of three companies of the UES Group.
  • Assisted Citibank with a full tax analysis of a $12m loan to Lumin, consisting of a $7m loan agreement and a $5m credit line facility agreement, to finance the activities of Lumin in Uruguay.

Bergstein Abogados

Tax remains a core focus for Bergstein Abogados, which fields a versatile and experienced team of lawyers in this area. Tax structuring and international tax are noted strengths, and the team also has a solid background in litigation. The department works closely with the firm's corporate practice to provide comprehensive support to its client base of multinational and domestic companies. Domingo Pereira focuses on international tax, and Jonás Bergstein brings together the disciplines of tax and corporate law, streamlining advice to clients needing both. On the litigation side, senior associate Guzmán Ramírez is the contact to note.

Practice head(s):

Domingo Pereira; Jonás Bergstein

Key clients

Deugro

Visanet Uruguay

Velcro USA

Nordex SE

Cisco Systems

NovaAgri

Adium Pharma

Sony Music Entertainment

Lexmark

Accenture

Work highlights

  • Advised Deugro on the tax structuring of its transport services for the construction of Finnish UPM’s second pulp mill plant in Uruguay.
  • Advised Sony Music on becoming partner in a new record label joint venture established in Uruguay.
  • Advised Voith on the tax consequences of receiving certain technical services for the construction of small-scale prototypes of machines and equipment, and studies and designs for their full-size construction.

Posadas

Posadas, Posadas & Vecino's full-service tax practice is particularly celebrated in the fields of international taxation and individual tax planning. To this end, the firm has an office in free trade zone Zonamérica, which is managed by tax practice co-head Raúl Vairo, who specialises in tax and commercial law and has vast experience advising local and international clients on establishing new ventures in the region. Alongside him in coordinating the tax department are Eduardo Ferrari, who is particularly active advising on the tax aspects of real estate projects, and public accountant Daniel González. Senior associate Guillermo Sena is a key contact for tax counselling and tax disputes.

Practice head(s):

Raúl Vairo; Eduardo Ferrari; Daniel González

Key clients

BTG Pactual

Lumin

Pedidos Ya

Administración Nacional de Usinas y Trasmisiones Eléctricas (UTE)

Trafigura

Gas Sayago

Grupo Biotoscana

Axionlog

Ventus

Roemmers

Mega Pharma

Work highlights

  • Advising Gas Sayago on tax aspects related to the sale of various assets, as well as on other tax aspects related to the closure of the project.
  • Assisting UTE with the day-to-day tax matters related to its development of the Valentines wind farm in Florida and Treinta y Tres.
  • Representing Cympay in a claim from the tax administration for over $1m.

Andersen Tax & Legal Uruguay

Andersen Tax & Legal Uruguay leverages the international reach of the wider firm to support its clients in multi-jurisdictional matters. The team in Montevideo is headed by Juan Ignacio Troccoli and is best known for its work in transactional tax and tax planning, and also handles contentious matters.

Blanco & Etcheverry

Blanco & Etcheverry's tax consultancy service works on designing corporate policy to maximise the tax benefits available to its clients both nationally and internationally. Other areas of expertise for the practice include tax litigation, application of treaties to avoid double taxation, and day-to-day management of taxes. Agustín Etcheverry is the key name to note.

Brum Costa Abogados

Brum Costa Abogados‘ tax department is best known for providing assistance to clients in the financial services sector, a key client being the Montevideo Stock Exchange. The team has both contentious and non-contentious capabilities, and Leonardo Costa draws on considerable experience in tax law, leading alongside María Paula Garat, whose varied expertise takes in tax, constitutional and public law.

Practice head(s):

Leonardo Costa; María Paula Garat

Testimonials

Attentive, agile, intelligent, diligent. That is why we work with them.

The team are very trained, they are intelligent and diligent.

Key clients

Bolsa de Valores de Montevideo

Nobilis Corredor de Bolsa

Cámara de Zonas Francas

Lifan Motors

Terna

Alur

Ducsa

HSBC

Gol TV

Work highlights

  • Assisted Montevideo Stock Exchange with compliance with CRS regulations; interpretation of the law; meetings with tax administration; and in reporting information.
  • Advised Gol TV on the establishment of the company in Perú and Ecuador.
  • Assisted Club Torque on the analysis and implications of Uruguayan tax law under different situations.

Deloitte Legal

The nascent practice at Deloitte Legal (Uruguay) is led by young partner Juan Bonet, a former senior associate at Guyer & Regules who was appointed head of the consultancy’s legal arm in Montevideo upon its opening in January 2020. Also handling banking and corporate matters, Bonet is specialised in international tax matters. Key support is provided by  associate Guillermo Lorbeer. The practice handles tax compliance, controversies and (tax-driven) restructurings, along with tax audits, the analysis of businesses’ tax situations, and advisory regarding tax inspections. The newly established legal arm of the firm is backed by the wider firm’s sizeable consultancy team -over 50 strong- and comprising both lawyers and CPAs.

Practice head(s):

Juan Bonet

Testimonials

They know the area to perfection. Always knowledgeable and willing. In the vanguard.

The advice is very complete combining knowledge from the legal and accounting point of view.’

The multidisciplinary aspect gives an added value over the competition; they are close and attentive to the needs of the client. Tax advice with legal, accounting and financial support generates a superior service.’

Key clients

InterEnergy Holdings

Prosegur España

Prosegur Uruguay

Trafigura

Suramericana

Kielder

Fanapel

HSBC

Siemens Gamesa

Unilever

Nike

Pepsico

Nestlé

BASF

Work highlights

  • Advisory on the tax strategy for the acquisition of three wind farms the sales of which were subject to certain restrictions due to tax exemptions.
  • Advised Prosegur España in the search of tax-labour efficiencies in Prosegur Uruguay.
  • Advised Kielder on the tax implications for the company of agricultural business activity in Uruguay.

Hughes & Hughes

A multidisciplinary team handles tax matters at Hughes & Hughes, routinely assisting with the range of tax matters involved in starting operations in Uruguay, as well as advising on the tax aspects of administrative issues. Associates Miguel Rocca and Alejandro Horjales are the key contacts, with experience in tax planning at the domestic and international level.

Practice head(s):

Haroldo Espalter; Alejandro Horjales; Miguel Rocca

Testimonials

H&H is a firm that has a very high technical quality and full service, managing to fully solve the company’s problems.

Key clients

Adidas Uruguay

Pestana Group

UPM Group

American Express

Tronem

Trafigura Group

Lojas Renner

Ineco Uruguay

Khiron Life Sciences Corp

Victorica Consignaciones

Sealed Air Uruguay

Work highlights

  • Advising Tronem on all the relevant tax aspects of its installation in Uruguay, and assisting the company in tax matters such as administrative procedures.
  • Assisting Surinor with all the relevant tax aspects of its installation in Uruguay and continues advising the company in tax matters.
  • Advising Ineco Uruguay on the relevant tax aspects of its operation in the country.

Olivera Abogados

An increasingly diverse client list of key domestic players as well as multinationals look to Olivera Abogados for tax advice in Uruguay. Recognised as 'specialists in various subjects', the broad offering is headed by Andrés Hessdörfer, who is highly regarded for his 'intimate knowledge of local and international taxation'. Alongside him, managing and founding partner Ricardo Olivera García has broad business law experience.

Practice head(s):

Andrés Hessdörfer; Ricardo Olivera GarcÍa

Testimonials

The seriousness, responsibility, confidentiality and constant support make the firm distinctive.

Andrés Hessdörfer is our point of contact and our permanent reference for inquiries and operational activities. We have resorted to him, both for specific consultations and for complex businesses, and not only does he always demonstrate an absolute disposition, but also an intimate knowledge of local and international taxation that solves problems for us on the go with absolute confidence.

Contact and knowledge of our company. The monitoring and advice of Andrés Hessdörfer, on the front line, provides a very valid support. Professional knowledge of the different areas in which we require advice.

Attention, knowledge, seriousness and professional follow-up at all times.

Andrés Hessdörfer is brilliant and the best lawyer in the area that I know.

The Olivera team has served us a lot as specialists in various subjects, a function that advises and collaborates with our professionals who are more generalists.

Key clients

Punta Carretas Shopping Center

Algonquin Power & Utilities

Associated Press

Bolsa Electrónica de Valores (Bevsa)

Gastón Bengochea Sociedad de Bolsa

Formula E Operations

Pembina Pipeline Corporation

Sportlink

Union Agriculture Group

Edding Group

Northpoint Commercial Finance

Work highlights

  • Acted for Union Agriculture Group in the biggest corporate and tax restructuring in its history, in order to reduce operative and tax inefficiencies, particularly regarding equity tax.
  • Assisting Edding Group with tax advice on its international trade strategy and, in particular, in its Latin American operations.
  • Advising Bevsa on the release of a new business line of exchange rate forwards within the financial market.