At Gálvez & Dolorier Abogados, the tax team is skilled in cases involving tax authority audits, transfer pricing and disputes, often for clients in the TMT, mining, energy and retail sectors. The team is collectively led by José Gálvez Rosasco, ‘a first-line professional’ who is experienced in domestic and international tax planning and tax issues related to M&A transactions; client favourite Silvia Muñoz-Salgado (‘great competence and diligence’; ‘clear when answering tax queries’), is a trusted advisor in intragroup financing and services; and Martín Mantilla Hidalgo, who demonstrates strength in acting for private and public sector clients in tax litigation – both administrative and judicial. The group also houses a strong associate bench; key names include Eduardo Guerra, who is well versed in income tax matters; Francis Gutiérrez, who provides capital markets-related tax advice; and Karem Carrillo, who handles complex transfer pricing cases; all three have over a ten years’ experience in tax matters.
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Profile

Work Department

Tax

Position

Silvia Muñoz Salgado, with over 25 years of experience in tax law, joined the firm as a partner in 2016. She previously worked at Rodrigo, Elías & Medrano Abogados for 10 years and spent 13 years as the legal manager at the Peruvian Tax Authority (SUNAT). Recognized as one of the few Peruvian experts in transfer pricing and intragroup financing and services, Silvia has made remarkable achievements in these areas.

Silvia's expertise in both consultancy and litigation in international taxation has established her as a leading lawyer in the field of legal tax defense in the country. Her prominence in the local professional market is also notable in academia. She is one of the main speakers and organizers of the international taxation seminars at the University of Lima, one of the most significant in the country. Over the past five years, these seminars have attracted top representatives from international academia (see: https://www.ulima.edu.pe/posgrado/agenda/v-seminario-de-tributacion-internacional).

Additionally, Silvia represented the country as a national speaker at the XXXI Latin American Tax Law Congress, organized by ILADT and held in Guatemala from October 24 to 27, 2022, focusing on the taxation of the digital economy.

Silvia's current clientele includes major local and international groups in key Peruvian industries, including TMT, mining and energy, the beauty industry, and finance.

During her time at SUNAT, she contributed significantly to the most important tax reform processes between 2000 and 2005, helping shape the current income tax law. In private practice, she has advised on legislative proposals, including for the Lima Stock Exchange regarding the tax treatment of factoring and capital gains exemption.

Career

Counsel at Rodrigo, Elías & Medrano Abogados (July 2014- December 2015).

Senior Associate at Rodrigo, Elías & Medrano Abogados (September 2006- July 2014).

Claims Manager of the Intendancy of Main National Taxpayers -SUNAT (August 2004-September 2005).

Specialized Professional of the Tax Standards Management – National Legal Administration – SUNAT (July 2001- August 2004).

Head of the Claims Section – Legal Department of the Regional Government of Lima – SUNAT (August 1993 – September 1999).

Languages

Spanish, English

Memberships

Member of the Lima Bar Association. Member of the International Fiscal Association – IFA Peruvian Group. Member of the Peruvian Institute of Tax Law (IPDT).

Education

Lawyer from the University of Lima, with outstanding mention unanimously (1993).

Master’s degree in Taxation from Georgetown University, Washington D.C., USA (2001).

Participant of the course “Advanced Transfer Pricing. Specific Aspects” taught by Vienna University of Economics and Business, Austria (2019).

Participant in the preparation seminar on “Principles of transfer pricing” given by the International Bureau of Fiscal Documentation (IBFD), Netherlands (April 9-13, 2018).

Participant of the course “Advanced Transfer Pricing (General Aspects)” taught by Vienna University of Economics and Business, Austria (2017).

“International Seminar on the Taxation of Non-Residents” OECD, CIAT and Ministry of Finance of Mexico, Mexico (2005).

“International Seminar on Taxation of Financial Markets” OECD, CIAT and Ministry of Finance of Mexico, Mexico (2004).

“International Seminar on International Tax Avoidance and Evasion” OECD, CIAT and Ministry of Finance of Mexico, Mexico (2004).

“International Seminar on Transfer Pricing” OECD, CIAT and Ministry of Finance of Mexico, Mexico (2003).

Participant in the Seventh Annual International Meeting on the Practical Application of Treaties for the Avoidance of International Double Taxation and Transfer Pricing, OECD, Paris, France (2002).

“International Seminar on Electronic Commerce and Tax Treaties”. OECD, CIAT and Ministry of Finance of Mexico, Mexico (2002).

VI Postgraduate Courses in Law, Politics and Criminology in Taxation. University of Salamanca, Spain (2002).

Diploma in Fundamentals of North American Law from Georgetown University, Washington D.C. (2000).

Diploma “Specialist in Taxation” from the Faculty of Accounting Sciences of the University of Lima (1995).

Participant in the IV Tax Administration Course, SUNAT (1993).

She also teaches international taxation and transfer pricing in the Master’s in Law program at Universidad de Lima.

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Testimonials

Collated independently by Legal 500 research team.

  • ‘The approach with a lot of practical application leads to very creative solutions.'

  • ‘Estudio Galvez and Dolorier Abogados have known our operations for years in addition to working with top and leading companies in Peru, which allows them to guide us in the best tax and business practices.'

  • ‘Stands out for the knowledge of the lawyers. In the case of Silvia Muñoz, she is clear when answering tax queries. I also highlight that she knows the stock market, which makes it possible for her to provide in detail and clarity the impact of tax regulations on this market.'

  • ‘José Gálvez not only masters tax legislation but also has a high capacity to understand company and business operations, finding points for improvement and optimisation. Martín Mantilla has been accompanying us for more than 10 years in the tax treatment of our operations in addition to the audits of the tax authority with good results.'

  • ‘José Galvez is a first-line professional who gets involved and solves problems effectively.'

  • ‘It is a personalised firm that provides tax services, being clear in its responses to queries of this nature.'

  • ‘I worked with Silvia Munoz, and she showed me an openness to supporting us as a client with the desire to take care of the company in the administrative process that we were carrying out together. It is an organic quality, difficult to achieve easily.'

  • ‘Silvia Munoz showed great competence and diligence in providing support, providing optimal and very useful support, because thanks to teamwork, a positive result was achieved as a result of the efforts before the tax authority.'

Key clients

  • Arca Continental Lindley
  • América Móvil – CLARO
  • Telefónica
  • Belcorp Perú
  • Trafigura del Perú
  • Statkraft Peru
  • Andina De Radiodifusión – ATV
  • Shahuindo
  • Los Portales
  • Tecnasa
  • Celima – Cerámica Lima
  • Tecnofarma
  • GNT Servicios Generales
  • Lima Stock Exchange & Cavali
  • Naviera Transoceanica
  • Consettur Machupicchu
  • Panasonic Perú
  • Consorcio Ejecutor Ica
  • Conalvias Construcciones
  • Clínica Ortega
  • GRUPO Marathon

Work highlights

Successfully advised Arca Continental Lindley on a tax audit, removing potential debts of up to $150m in preliminary observations.
Successfully represented Panasonic del Peru before the Tax Court, creating a precedent in relation to transfer pricing objections concerning its import operations of appliances.
Advised Telefónica del Perú on its 2017 tax audit, effectively neutralising potential assessments related to intragroup expenses.