Mexico - Tax Lawyers & Law Firms - Latin America | Chambers and Partners
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Latin-America Guide

Tax — Mexico

Overview

OVERVIEW OF THE LEGAL TAX PRACTICE IN MEXICO: CHAMBERS LATIN AMERICA 2018

Mexico's legal tax practice has undergone many changes over the last several decades. Years ago, the legal tax practice was dominated by accounting firms which were entrusted with most of the significant tax work in Mexico. Lawyers did not play an important role and, in many cases, were only responsible for assisting accountants in tax controversies. Since only a handful of full-service law firms had significant tax practices, it was not uncommon that law firms relied on accounting firms for transaction-related tax issues.

Today, things are very different. Mexico’s legal tax practices are booming. It is inconceivable to think of a major full-service law firm without a tax practice. Tax lawyers play an important role in day-to-day business transactions and are no longer viewed as ancillary support for accountants. In fact, tax lawyers provide the primary tax advice in many business transactions. Accounting firms have consequently grown their legal tax departments and, together with in-house accountants, provide integrated tax advice to clients.

The relevance of legal tax boutiques in Mexico is ever-increasing. Traditionally, legal tax boutiques in Mexico were only active in representing clients in tax litigation and were not actively involved in other areas. Now, legal tax boutiques provide clients with a wide range of tax services and are no longer viewed exclusively as tax litigators.

Tax litigation in Mexico has also evolved greatly over the past few years. Tax cases were previously litigated in Mexico by arguing failure to comply with formalities in the process by the tax authorities. Amparo lawsuits were also common. An amparo lawsuit challenges the constitutionality of a provision in the tax statute. Historically, most major tax reforms have been challenged by taxpayers through amparo lawsuits, and many times the decisions were favourable to the taxpayers. The consequence was that some taxpayers were exempted from the application of certain provisions of tax statutes until legislative changes were made to eliminate the unconstitutionality of these provisions. As legal tax practices have evolved, so has tax litigation in Mexico. There are still tax cases in which the main arguments are based on flaws in the statutes, but most of the major tax litigation has become very sophisticated. In addition, when challenging the constitutionality of recent tax provisions, the Mexican Supreme Court has frequently ruled against taxpayers.

Consistent with the evolution that tax litigation has had in Mexico, in 2017, amendments to Mexican tax legislation became effective. Therefore two additional instruments are now available, which allow taxpayers to challenge assessments issued by the Mexican Treasury. The first is the administrative appeal exclusively for substantive matters. This new appeal is resolved by the legal section of the Mexican Treasury. The second is the new trial for tax cases that deals exclusively with substantive issues. A new section of the Tax Court was created to resolve this new trial. These two instruments were designed to analyse the real substance of transactions, disregarding arguments about formalities.

The elimination of trade and investment barriers that stemmed from the adoption of the North American Free Trade Agreement, and the fact that Mexico was included as a member of the Organisation for Economic Co-operation and Development, has resulted in the legal tax practice in Mexico transforming from a domestic-oriented practice to a more international practice. Many of the recent tax controversies arising in Mexico have to do with international tax topics, whereas in the past, few Mexican practitioners dealt with international tax issues. Mexico has a network of over 50 international treaties to avoid double taxation, allowing businesses established in Mexico to benefit from the advantages that these treaties bring to international transactions. The Mexican legal tax practice currently has relevant practitioners with sound international tax capabilities that make multinational corporations confident that they will obtain the same sophisticated tax advice in Mexico as they do in other jurisdictions.

For the most part, Mexico has a tax system that is anchored in federal taxes, such as income tax and value-added tax (others include import and export taxes, social security and other excise taxes). The current corporate income tax rate is 30% for entities, and the highest tax rate for individuals is 35%. Additionally, Mexican residents are taxed on their worldwide income. The states levy some minor taxes such as payroll tax, property tax and taxes on hotel accommodations, as well as through co-operation agreements through which they are also entitled to collect federal taxes in certain circumstances. The system is indexed to neutralise the effects of inflation and has undergone several major reforms in recent years.

Foreign investors doing business in Mexico should be aware that, as opposed to many other countries where substance prevails over form, the tax system in Mexico has traditionally been very formalistic. It would be fair to say that the real substance of transactions has not been as relevant as their formalities. However, the system has evolved into one that cares for substance more than before, which is evidenced by the implementation of the new administrative appeal and the new trial that both focus on the real substance of transactions.

The government of President Enrique Peña Nieto promised that an important and significant reform of the Mexican tax system would take place in the second half of 2013, although the reform enacted on 1 January 2014 was considered to have less significant an impact than expected. The following are among the most relevant aspects of the aforementioned reform: (i) the flat tax was eliminated; (ii) the consolidation for tax purposes was eliminated; (iii) the tax on cash deposits was eliminated; (iv) a new tax on dividends of 10% applicable to foreign residents and Mexican individuals was included; (v) the gains from sales of shares through the Mexican stock market are now taxed at a rate of 10%; (vi) the top individual income tax rate was increased from 30 to 35%; and (vii) activities in the border region are now subject to the general 16% rate of VAT (instead of the former preferential 11%) rate.

Mexico had an important energy reform resulting from the December 2013 amendments to the Mexican Constitution that allows the participation of the private sector in the oil and gas market. As part of said reform, on 11 August 2014, the Hydrocarbons Revenue Law was published. Among other things, this new tax law sets forth the rules under which the private sector and the State Productive Companies make payments to the Mexican federal government (conducted through the newly formed Mexican Petroleum Fund) derived from revenues associated with contracts or assignments.

Additionally, in October 2015, rules for the creation of trusts for the investment in energy and infrastructure (the so-called “FIBRA E”) were published. Since then, several tax rules have been released (the latest ones were published on 1 April 2016) to promote and enhance this new investment vehicle that should provide access to private investment primarily in mature cash-generating projects related exclusively to the energy and infrastructure sectors.

Finally, on 1 January 2016, amendments to Mexican tax statutes were enacted to require from multinational corporations the filing of a master information return, local information return and Country-by-Country report on a yearly basis. These new rules resulted from the application of Action Plan 13: Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting of the OECD/G20 Base Erosion and Profit Shifting Project. Qualified multinational corporations are required to make the aforementioned filings for the first time in 2017.

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Chevez, Ruiz, Zamarripa y Cia., S.C. - Tax

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Band 1

第一等

Commentary from the Chambers Latin America guide

Basic facts about the department
- approximately 22 qualified lawyers

What the team is known for Standout tax powerhouse maintaining a leading position in this field. Acts as counsel to market-leading clients on a comprehensive range of tax mandates including the fiscal impact of corporate transactions and tax planning. Particularly strong reputation in the tax litigation space, including both administrative and constitutional matters. Offers further expertise in international taxation issues such as treaty review and transfer pricing.

Strengths The firm earns widespread plaudits from sources, with clients highlighting its "outstanding service." Another commentator adds: "You cannot deny that the firm has a very good reputation in tax. Their litigation team is exceptional, and highly knowledgeable about both our business and the different factors that affect it."

Interviewees go on to report: "This is one of the main tax firms in Mexico, and its exceptional lawyers have a level of specialisation which makes them unique."

Notable practitioners

Leading figure Manuel Sáinz Orantes is held in high esteem by peers, who credit him with a prestigious presence in the market, adding: "He is a very good lawyer who is highly knowledgeable and respected in the tax field." Sources laud him for his reputation in the tax litigation arena specifically, in which he has over 30 years of experience.

Partner Alejandro Torres Rivero is deemed by market sources to be highly specialised in the field of tax litigation, with a particular focus on amparo proceedings. Peers laud him as "a great litigator."

Ricardo Cervantes receives praise from clients, who state: "He has a skill that we appreciate, which is to always play devil's advocate and put himself in the position of the regulator; this ensures that we have a robust argument."

Department profile by Chevez, Ruiz, Zamarripa y Cia., S.C.

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Basham, Ringe y Correa S.C. - Tax

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Band 2

第二等

Commentary from the Chambers Latin America guide

Basic facts about the department
- 5 partners
- 21 other qualified lawyers

What the team is known for Highly regarded firm with a respected tax department representing a range of clients, including notable names from the mining and automotive spaces. Active in M&A-related tax issues, as well as wider consulting on Mexico's tax legislation. Strong experience in tax litigation, including amparo proceedings, as well as transfer pricing and wealth management.

Strengths Clients say: "We are very satisfied with the service. Everything is urgent for us, so they are good at being flexible with hours and are always open to any feedback that we may have."

Work highlights Represented a multinational mining company in amparo proceedings relating to mining fees put in place in 2014. The case is currently being considered by the Supreme Court.

Significant clients Minera Peñasquito, Aerovías de México, Volkswagen.

Notable practitioners

Well-known practitioner Alejandro Barrera Fernández is lauded by peers as "outstanding in tax issues; when you ask him for anything, he always adds value." Sources also highlight his professionalism. He leads the firm's tax consulting practice and advises both corporations and individuals.

Gerardo Nieto leads the firm's tax litigation practice, focusing on contentious tax work such as administrative and constitutional litigation proceedings. Peers say: "He is a good tax litigator and is devoted to his clients." He offers further expertise in tax audits, restructurings and planning.

Partner Gil Zenteno Garcia has 25 years of experience in tax issues. He focuses his practice on contentious tax mandates, including amparo proceedings. Peers describe him as "a tough litigator." Peers also highlight his experience and activity in matters concerning international trade.

Department profile by Basham, Ringe y Correa S.C.

General Overview 

Tax 

Every business plan or model must comply with domestic and international tax provisions. For this reason, Basham, Ringe y Correa, S.C. assists our clients in meeting their tax obligations, under the Law.

Aware of our clients’ concerns regarding the frequent amendments to tax provisions, Basham, Ringe y Correa, S.C. offers a wide range of tax planning services to maximize the efficiency of their transactions.

Accordingly, we relentlessly strive to find synergies between our clients’ business plans or models and the tax provisions. We know every clients expects objective advice, sound strategies and commitment from their advisors. For this reason, we offer comprehensive and innovative tax solutions.

In light of the level success Basham, Ringe y Correa, S.C. has achieved in Mexican courts. The Firm is very highly regarded among public officials, including, judges and justices from the Supreme Court.

Our tax attorneys have pursued graduate tax studies in domestic and foreign universities. Likewise, they actively participate in domestic and foreign professional associations. This blend of academic and practical experience makes them true leaders in the market.

Basham’s leadership in taxation is widely spread both nationally and internationally. For example, in 2010, the firm was recognized in the tax area as the "Best Tax Litigation Firm in Mexico" by the International Tax Review.



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DLA Piper Gallastegui y Lozano - Tax

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Band 2

第二等

Commentary from the Chambers Latin America guide

Basic facts about the department
- 3 partners
- 7 other qualified lawyers

What the team is known for Highly regarded boutique tax practice recognised for its expertise in the fiscal aspects of M&A transactions, as well as contentious tax matters. Active in local tax controversy issues as well as complex amparo proceedings. Additional experience in advising corporate clients on matters pertaining to foreign trade and customs law.

Strengths A client states: "What I like about the lawyers is that they are incredibly experienced; they have extensive experience in this area, including from the government's side as well. They are pragmatic and effective, but don't propose outlandish solutions."

Notable practitioners

Leading individual Ramiro González Luna is highlighted by peers, who commend his consolidated practice. They go on to say: "He is an extraordinary lawyer on the transactional and consulting sides. He has been very successful for many years." One client adds: "I would definitely recommend him for tax matters," adding: "He is a very good tax lawyer with a lot of experience and training in this field."

Department profile by DLA Piper Gallastegui y Lozano

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EY Mexico - Tax

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Band 2

第二等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Heads of department: Manuel Solano and Enrique Ramírez Figueroa
- approximately 17 qualified lawyers

What the team is known for Highly respected international tax consulting firm garnering significant praise for its presence across the tax ambit. Areas of activity include tax litigation, consulting on international tax issues such as transfer pricing, and tax planning. Highlighted for its activity in Mexico's energy sector, assisting a range of clients from the oil and gas space.

Strengths Sources state: "The firm is an important tax practice in Mexico and is particularly good in international taxation issues."

Notable practitioners

Leading partner Enrique Ramírez Figueroa heads the firm's tax litigation practice. Peers single him out for praise, lauding him as "a great litigator." Market commentators go on to say: "He is one of the few litigation practitioners that really understands business, so he can also do consulting work. His practice is very comprehensive."

Partner Nora Morales receives ample praise from peers. They highlight her as "a jewel of the practice," and enthuse: "She is amazingly intelligent and a great lawyer." Sources add: "She works as both a litigator and an adviser and is very good at rendering tax advice."

José Pizarro enters the rankings after attracting strong praise from sources, who state: "He is a great lawyer. You can ask him anything and he has an opinion. He is one of the reasons the firm is doing well."

Department profile by EY Mexico

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Sánchez DeVanny Eseverri, S.C. - Tax

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Band 2

第二等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Heads of department: Ricardo León Santacruz, Guillermo Villaseñor Tadeo and Abel Francisco Mejía Cosenza
- 3 partners
- 12 other qualified lawyers

What the team is known for Highly regarded full-service firm active across the spectrum of tax mandates, including both transactional and contentious work. Frequently advises clients on tax controversy issues, including representation throughout the auditing process and any subsequent administrative litigation or mediation. Maintains a strong consulting practice, counselling companies on transfer pricing and high net worth individuals on fiscal restructurings.

Strengths Clients praise the firm's tax team, stating: "They have a lot of expertise and can respond to any query that we may have. They also have contacts in many countries and understand how Mexican tax law relates to that of other jurisdictions."

Work highlights Acted as lead counsel to House of Threads as seller on the tax liability of Wurth Group's acquisition of the Alabama-based company.

Significant clients Arca Continental, Nissan, Hewlett-Packard, Eaton Corporation, Banque Pictet.

Notable practitioners

Partner Ricardo León Santacruz focuses his practice on the fiscal impact of corporate transactions, advising on efficient tax structures for M&A deals, as well as tax restructurings. He remains an active figure in the transfer pricing field. Clients appreciate his advice, stating: "He is very well versed in Mexican and cross-border tax matters and explains tax law extremely well." Sources add: "He is a truly distinguished tax practitioner."

Clients say that Abel Francisco Mejía Cosenza "is able to work with clients of all profiles, including the more demanding ones; he knows how to work with different personalities and provides good answers to our questions." He advises ultra high net worth individuals on estate planning and restructurings, as well as corporations on the tax aspects of cross-border transactions.

Partner Guillermo Villaseñor Tadeo is active across the transfer pricing and litigation fields, handling contentious mandates against the Mexican tax authorities on behalf of multinational clients, as well as tax audits. Clients single him out for praise, saying: "You can discuss anything with Guillermo, and if he isn't an expert in that particular area, he can refer you to someone who is."

Up-and-coming individual Mariana Eguiarte Morett receives recognition from sources, who enthuse: "She is solid from a technical perspective, bilingual, and has a lot of experience in global tax matters. She is also always available." Her practice centres on issues of corporate taxation.

Department profile by Sánchez DeVanny Eseverri, S.C.

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Turanzas, Bravo & Ambrosi - Tax

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Band 2

第二等

Commentary from the Chambers Latin America guide

Basic facts about the department
- 7 partners
- 30 other qualified lawyers

What the team is known for Respected tax boutique offering a range of relevant expertise spanning complex tax controversy issues and matters concerning international taxation, such as transfer pricing. Also active in corporate taxation, handling the tax aspects of transactional mandates. Continues to advise individuals on estate planning and maintains notable market participation advising prominent corporations active in Mexico's energy sector.

Strengths Clients attest: "They are really specialised tax lawyers who are good for sophisticated matters. They add extra value by way of their ability to understand non-Mexican legal concepts."

Work highlights Advised Noble Corporation on its appeal before the Mexican tax authorities to recover tax credits worth USD50 million, after recalculating the value of said credits.

Significant clients Pernod Ricard, Halliburton, DuPont, PINFRA, Avon.

Notable practitioners

Leading practitioner Mauricio Bravo Fortoul focuses his practice on tax litigation, and is highly active advising clients from the energy sector. Clients offer their praise of his professional support, stating: "He is a person that speaks with absolute clarity, hence he is able to make his clients understand legal concepts even when they are generally unfamiliar with legal terms. He keeps us informed as to what our options are in any eventuality."

Senior partner Mauricio Ambrosi Herrera is active in matters pertaining to international taxation, particularly transfer pricing. Clients enthuse: "He is a very good lawyer with a lot of experience and great English skills." Sources go on to comment: "He is intelligent, hard-working and reliable; he is also both an adviser and a litigator, which in tax is very helpful."

Pedro Ramírez Mota Velasco is involved in the firm's most complex matters within the field of estate planning. Clients also highlight him for his activity in international matters, saying: "He is very intelligent and an expert in international taxation. He is a first-rate lawyer."

Partner Carl Koller is singled out for praise by clients, who describe him as "someone who provides a quick and effective response," adding: "He is very client-oriented and pragmatic." Peers highlight that "he is a real professional," also making reference to his technical expertise.

Angel Turanzas Díaz offers expertise in matters relating to both corporate and individual taxation. He represents clients from a range of sectors including energy and transportation. Clients describe him as "an intelligent and talented lawyer."

Department profile by Turanzas, Bravo & Ambrosi

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Anaya Abogados Asociados, S.C. - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Heads of department: Edgar Anaya, Fabiola Díaz and Agustín Meixueiro
- 2 partners
- 5 other qualified partners

What the team is known for Highly regarded tax boutique engaged in representing a range of clients, particularly from the energy sector, in administrative litigation against Mexico's tax authorities. Additional expertise in advising on fiscal restructurings and significant involvement in the wealth management arena, advising high net worth families on tax planning issues.

Strengths Clients appreciate "the constant communication that the team members maintain with us, as well as their legal analyses and knowledge of the tax authorities."

Work highlights Represented Grupo Nieto in several tax litigation cases relating to the company's administrative appeal to reclaim USD40 million from the Mexican tax authorities.

Significant clients Summum Energy, Almacenadora del Valle de México, Andritz Hydro, Viacom International Media Networks The Americas, Gazprom.

Notable practitioners

Senior partner Edgar Anaya focuses his practice on the tax planning and litigation areas. Clients describe him as "an approachable lawyer who provides practical and forward-thinking solutions to avoid lengthy processes." Sources add: "His approach emphasises responsiveness and providing good support for the legal recommendations that he makes."

Fabiola Díaz leads the firm's tax consulting group, advising both individuals and corporations. Clients appreciate her support, as one interviewee points out: "I think she has wide knowledge across the tax and legal spheres; she has great analytical skills and constantly seeks alternatives and solutions."

Department profile by Anaya Abogados Asociados, S.C.

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Arias, Meurinne y Rodríguez, S.C. - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- 5 partners
- 15 other qualified lawyers

What the team is known for Significant boutique tax practice focusing on tax litigation. Provides additional support to clients in the tax consulting and planning areas. Also assists clients with the tax auditing process, handling any administrative litigation arising from such matters at the local and federal levels.

Strengths Clients assert: "They are very good lawyers from a technical perspective. They are also creative and find new solutions to problems."

Notable practitioners

Pedro Arias Garrido is singled out by sources for his activity and expertise in the administrative litigation space, both within the tax sphere and beyond. Peers say: "He is a good lawyer, a tough litigator and someone who does things properly." One market commentator goes on to mention: "I would recommend him to my own clients."

Luis Meurinne focuses his practice on tax consulting and planning, leading the firm's endeavours in both of these areas. He has also made a number of relevant academic contributions to the Mexican tax space.

Department profile by Arias, Meurinne y Rodríguez, S.C.

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Baker McKenzie - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Head of department: Luis Carbajo-Martínez
- 16 partners
- 57 other qualified lawyers

What the team is known for Respected global name with strong coverage of the Mexican market and sizeable tax department. Solid involvement in the tax controversy area, representing clients in negotiations before the Mexican tax authorities, as well as in administrative litigation matters. Additional expertise in tax consulting and transfer pricing.

Strengths Clients appreciate that "the firm's lawyers are very much aligned with international practices and have a strong presence in the market."

Work highlights Assisted Lear Corporation with a tax audit, a subsequent administrative appeal regarding its audit, and a tax reorganisation in the context of the company's acquisition of Albert Trostel Group.

Significant clients PKC Group, adidas, WestRock, Anadarko.

Notable practitioners

Clients credit department head Luis Carbajo-Martínez with "ample experience in tax matters," adding: "He is also knowledgeable about maquiladora and customs issues, which complements his tax knowledge well." Peers describe him as "someone who really contributes to discussions, with distinctive expertise in tax issues relating to hydrocarbons."

Partner Jorge Narváez-Hasfura is highly regarded by clients, who state: "He is a very experienced partner who manages client relationships very well. He instils trust in his clients." His practice centres on issues relating to corporate taxation, transfer pricing and tax restructurings.

Ulises Castilla has experience in both the public and private sectors, having spent time working at the Mexican tax authorities. His practice focuses on tax litigation and strategic consulting. Peers report: "He is definitely one of the strongest lawyers that the firm has at present."

Department profile by Baker McKenzie

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Creel, García-Cuéllar, Aiza y Enríquez, S.C. - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Head of department: Alejandro Santoyo
- 4 partners
- 20 other qualified lawyers

What the team is known for Prominent transactional player fielding a highly regarded tax team comprising individuals with experience in both the private and public sectors. Active in advising on the tax liability of corporate transactions, whilst maintaining strong tax controversy capabilities including administrative litigation against the authorities.

Strengths Clients enthuse: "The firm's tax group is great; they are really good at directing in-house counsel and explaining issues to us, working seamlessly and efficiently with the firm's transactional group."

Work highlights Advised PINFRA on the tax aspects of its issuance of Mexico's first FIBRA E, a new asset class in the country's capital markets used to fund energy and infrastructure projects.

Significant clients National Football League, Blackstone, Oracle, UBS, First Reserve.

Notable practitioners

Clients are full of praise for practice leader Alejandro Santoyo, whom they describe as "client-focused, very knowledgeable and responsive." Sources highlight his level of specialisation, saying: "He is good at advising on the tax aspects of capital markets deals and has a lot of experience in this field. He also understands how the tax system works so if you put those two things together, you get a really good final product."

Partner Omar Zúñiga is recognised for his experience spent as both external and in-house counsel. Clients highlight his drafting skills, stating: "When we receive documents from him, they are excellent and never burdensome to read. He has a real understanding of Mexican law outside of the tax area as well."

Jorge Correa Cervera enters the rankings after receiving praise from sources. One interviewee comments: "He is really responsive, which I think is an underrated attribute in lawyers. He is very intelligent when handling clients; he provides all the right information without overloading us with details."

Department profile by Creel, García-Cuéllar, Aiza y Enríquez, S.C.

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Deloitte Legal Services - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- approximately 3 qualified lawyers

What the team is known for Significant global auditing firm praised for its expertise in matters of international taxation such as transfer pricing. Offers further assistance to clients on specific issues such as individual taxation of expatriates. Client roster includes a number of notable multinationals.

Strengths Sources highlight: "The lawyers are very client-oriented, provide clear responses to our queries, and summarise the challenges to our business well."

Notable practitioners

Eduardo Revilla Martínez is highlighted by peers for his specialisation in tax matters. Sources say: "He is very present in the tax area." He is active in a range of mandates, among which tax litigation features prominently. He is also recognised as a frequent contributor to notable publications regarding tax law in Mexico.

Partner Jorge Jiménez Cañizares receives praise for his knowledge of tax issues affecting the insurance sector, as well as the financial services arena in general. He specialises in consulting and tax litigation matters.

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Despacho Parás - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- 3 partners
- 3 other qualified lawyers

What the team is known for Well-regarded boutique tax practice focusing on advising clients on the tax aspects of corporate transactions, with further expertise in the restructuring of companies' tax affairs. Fields a team comprising both qualified lawyers and accountants, and is also active in the tax planning arena.

Notable practitioners

"Unquestionable market leader" Jorge Covarrubias Bravo is widely commended by peers for his role in representing notable names in the Mexican market from key sectors including telecommunications. One peer reports: "He is a strong practitioner in the sense that he represents key clients and is a capable lawyer; for these reasons, I consider him a first-rate professional."

Department profile by Despacho Parás

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Gardere, Arena y Asociados, S.C. - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Heads of department: Roberto Arena Reyes Retana and Fernando Camarena Cardona
- 2 partners
- 3 other qualified lawyers

What the team is known for Well-known Mexican offering of US-based firm focusing on tax consulting and specialised litigation. Advises a range of clients from the Mexican oil and gas and insurance sectors, acting as counsel to large and medium-sized players. Remains active in base erosion and profit shifting issues, as well as in amparo proceedings.

Strengths Clients enthuse: "Gardere, Arena y Asociados stands out from other firms for its creative and business-oriented thinking; they really understand our company and our legal needs, which is why they are able to anticipate them."

Work highlights Represented Herbalife and its Mexican subsidiary in an administrative appeal against an 8% tax on the sale of high-calorie food in Mexico.

Significant clients Amazon, Brightstar, Whirlpool, Tesco Corporation, Trafigura.

Notable practitioners

Clients are full of praise for partner Roberto Arena Reyes Retana. They say: "He is a highly sophisticated, respected and experienced lawyer. His financial knowledge makes his tax advice stand out, whilst in terms of strategic decision making, he also provides highly valuable suggestions." Sources go on to add: "He always contributes creative ideas and is very helpful as counsel due to his experience."

Partner Fernando Camarena Cardona is singled out for praise by clients, who state: "He is a great lawyer who always shows an understanding of our business as a whole, not simply the question at hand; this makes him a great tax lawyer but also a notable business adviser for our company. He always goes beyond simply resolving queries, seeking real solutions to our problems."

Department profile by Gardere, Arena y Asociados, S.C.

The cross-border team of leading tax attorneys at Gardere provides clients sound advice and guidance through even the most daunting of circumstances. From the first stages of planning and structuring to the resolution of tax disputes with governmental authorities, we help companies doing business in Mexico and worldwide achieve tax solutions in accordance with their specific needs. We bring to the table a proven track record in managing cross-border and domestic tax disputes coupled with an expertise in corporate and customs law.

Representative tax services typically include:

  • Tax planning (domestic and international)
  • Transfer pricing (including negotiation with competent authority)
  • Tax mediation and litigation
  • Administrative and constitutional challenges
  • Negotiations to obtain tax incentives
  • Customs regulations
  • Audits

Gardere also provides its clients with advice in connection with reporting and disclosing requirements abroad resulting from tax contingencies in Mexico such as FIN48.

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Jáuregui y Del Valle, S.C. - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Heads of department: Luis Gerardo Del Valle Torres and Eduardo Medina Zapata
- 3 partners
- 7 other qualified lawyers

What the team is known for Established tax player offering services across the tax arena. Active in tax litigation, representing clients before the Mexican tax authorities. Also remains present in tax consulting, counselling a range of players on efficient tax structures for corporate transactions. Additional expertise in estate planning at both the national and international level.

Strengths Sources say: "The lawyers are really good at explaining what your options are. In general, the firm is extremely good."

Work highlights Advised Walton Street Capital México on the tax structure of its CKD issuance, worth approximately USD480 million.

Significant clients American Industries, Southern Cross Group, FIBRA Terrafina, Planigrupo CKD, Prudential Global Investment Management.

Notable practitioners

Key partner Luis Gerardo Del Valle Torres receives endorsements from clients, who say: "He has really earned our trust because he knows his clients and is a highly effective lawyer. We really appreciate the opportunity to work with him." They go on to comment: "What comes to mind about him is his complete professionalism and profound knowledge of both national and international tax and legal concepts."

Department profile by Jáuregui y Del Valle, S.C.

Department profile not yet provided by Jáuregui y Del Valle, S.C.. Please see their firm profile.

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Natera, S.C. - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- 2 partners
- 4 other qualified lawyers

What the team is known for Multidisciplinary team fielding professional expertise from both the legal and accounting arenas. Offers specialised services in consulting and litigation, with significant expertise in international matters such as transfer pricing and foreign trade. Also advises on the tax liability of inbound investment.

Notable practitioners

Key partner Christian Natera is highlighted by peers for his technical expertise in tax issues. They say: "He has a strong client base and was also trained as an accountant, which means that technically speaking he is very capable." He advises on a range of tax issues including inbound investment, litigation and transfer pricing.

Patricia Lopez Padilla gains praise from peers for her visibility in the tax field. She focuses her practice on tax litigation.

Department profile by Natera, S.C.

Department profile not yet provided by Natera, S.C.. Please see their firm profile.

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Ortiz Abogados Tributarios - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- 3 partners
- 4 other qualified lawyers

What the team is known for Boutique tax practice focusing on representing clients in tax litigation, as well as providing broad tax consulting services. Active in advising clients on transfer pricing and wealth management issues, acting as counsel to significant players from the telecoms, healthcare and construction spaces.

Notable practitioners

Esteemed practitioner Gabriel Ortiz Gómez earns recognition from clients, who state: "Gabriel is extraordinary when it comes to interpreting tax law and representing clients before the SAT." He is highlighted by peers for his many years of experience in the tax field, as well as his level of specialisation in tax litigation.

Department profile by Ortiz Abogados Tributarios

Department profile not yet provided by Ortiz Abogados Tributarios. Please see their firm profile.

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PricewaterhouseCoopers (PwC) México - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- approximately 5 qualified lawyers

What the team is known for Respected international tax auditing firm handling a range of relevant matters for local and international clients. Areas of expertise span the tax aspects of M&A, consulting and tax restructuring. Also active in administrative litigation.

Strengths A client enthuses: "This is a very knowledgeable team that demonstrates an awareness of the impact of tax law on a range of industries."

Notable practitioners

The "very well-respected" Eduardo Méndez Vital garners endorsements from peers for his experience in the field of tax litigation.

Partner Sandro Castañeda is described by a peer as "a relevant player involved in large cases." He handles litigation and international tax treaty interpretation.

Department profile by PricewaterhouseCoopers (PwC) México

Department profile not yet provided by PricewaterhouseCoopers (PwC) México. Please see their firm profile.

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SMPS Legal - Tax

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Band 3

第三等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Head of department: Jorge San Martin Elizondo
- 4 partners
- 7 other qualified lawyers

What the team is known for Strong tax team involved in both consulting and contentious mandates. Acts for leading players from the energy and retail spaces, also representing notable funds. Frequently seen acting as counsel to both private clients on estate planning and to large corporations on the tax structures for transactions.

Strengths One source notes: "They listen to me and they understand me. They don't abandon their opinions easily, but they are always open to changing their mind in light of the evidence."

Work highlights Advised Grupo Axo on the tax aspects of its joint venture with US-based company PVH.

Significant clients Nexxus Capital, Danone, TransCanada Corporation, Fibra Danhos, ATCO.

Notable practitioners

Partner Jorge San Martin Elizondo is highly specialised in mandates requiring knowledge of tax structures for inbound investment, advising on M&A transactions, tax restructurings for existing companies and international taxation. A client enthuses: "He quickly understands the relevant issues at hand to develop creative solutions."

Ana Paula Pardo Lelo de Larrea advises both corporations and individuals on the tax aspects of corporate transactions. Her expertise spans transfer pricing, tax restructuring and tax planning. Clients commend her English language skills and international experience, adding: "She is an amazing adviser who was able to solve all our problems and doubts."

Associate-to-watch Federico Scheffler receives praise from sources, with clients particularly highlighting his rapid response times. He focuses on tax planning and tax structures for M&A transactions.

Department profile by SMPS Legal

SMPS Legal is a leader in the optimization of tax structures and M&A tax related issues. The Tax Practice is uniquely qualified as it is a fully integrated consulting and litigation Tax Practice whereby all members of the SMPS Legal Tax Team provide both consulting and litigation services, with a clear vision of the financial and legal aspects of every issue impacting the client.

The SMPS Legal Tax Practice assists  its  clients in complex transactions involving financial technicalities and contingencies banking on the strong financial and litigation backgrounds of all its members. This directly translates into a comprehensive handling of each case, tailored to better serve the client and providing tangible added value thereto.

SMPS Legal offers multidisciplinary advice in all matters related to  tax,  enforcement of international treaties and implementation of national and foreign structures for residents in Mexico and abroad, as well as tax and administrative litigation.

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Calderón, González y Carvajal, S.C. - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- approximately 9 qualified lawyers

What the team is known for Recognised tax boutique providing services in administrative litigation before Mexican tax and customs authorities. Also renders general tax advice to clients regarding tax auditing and the interpretation of international tax treaties. Fields a team comprising both legal and accountancy expertise.

Notable practitioners

A source notes that Alejandro Calderón Aguilera "is extremely active in the tax space," with another peer lauding him as "a dedicated lawyer, for whom I have a lot of respect." He offers expertise of Mexican tax legislation, as well as its Anglo-Saxon counterpart, advising clients on matters pertaining to double taxation and transfer pricing.

Department profile by Calderón, González y Carvajal, S.C.

Department profile not yet provided by Calderón, González y Carvajal, S.C.. Please see their firm profile.

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Calvo Nicolau y Márquez Cristerna, S.C. - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- 3 partners
- 11 other qualified lawyers

What the team is known for Dedicated tax practice offering both preventative tax advice on strategic planning and defensive representation in tax controversy cases. Enjoys a strong market reputation for its years of experience in tax matters of a contentious nature.

Notable practitioners

Partner Oscar Marquez is qualified as both a lawyer and an accountant. He mainly advises on contentious matters such as administrative litigation before the Mexican tax authorities. Peers note his involvement in representing individuals.

Senior statesman Enrique Calvo Nicolau garners plaudits for his years of experience in the tax arena. One peer says: "He is a very respectable lawyer who really stands out in the tax practice area," whilst another enthuses: "He is an institution; he has been around for many years."

Department profile by Calvo Nicolau y Márquez Cristerna, S.C.

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Creel Abogados - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Heads of department: Carlos Martínez and Javier Portas
- 2 partners
- 5 other qualified lawyers

What the team is known for Well-known corporate transactional firm with a specialised tax department. Recognised for its presence in the tax field advising on the fiscal aspects of corporate transactions, acting as counsel to a range of funds active in the Mexican market. Team is also very involved in customs issues.

Strengths A source notes: "The service has always been impeccable and the partners always assist you directly."

Work highlights Acted as counsel to Kerzner Palmilla Hotel Partners in relation to its corporate restructuring, which required advice on transfer pricing and tax compliance spanning three jurisdictions.

Significant clients Portinox, EFM Capital, Altum Fund, Belcorp, Xylem.

Notable practitioners

A source enthuses that Javier Portas Ledesma "is a great professional with excellent legal knowledge. He proposes creative legal solutions and is always present throughout the duration of the matter." He frequently advises on mandates concerning international taxation.

Department profile by Creel Abogados

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Galicia Abogados, S.C. - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- approximately 6 qualified lawyers

What the team is known for Recognised transactional powerhouse entering the rankings due to its flourishing practice in the tax field. Experienced team focusing on tax litigation and consulting, offering expertise in double taxation, efficient tax structures for transactions, and tax auditing.

Notable practitioners

Sources highlight Gabriela Pellón Martínez's recent move to Galicia Abogados, saying: "She is very knowledgeable and is going to do very well at her new firm." She earns plaudits for her expertise in tax litigation.

Since publication, Arturo Pérez Robles has left the firm.

Department profile by Galicia Abogados, S.C.

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Goodrich Riquelme y Asociados - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Head of department: Sergio Ruiz Lopez
- 1 partner
- 2 other qualified lawyers

What the team is known for Established player in Mexico's tax arena advising a range of notable names from the energy, natural resources and pharmaceutical industries. Active in the area of tax amparos, as well as general administrative litigation before the tax authorities.

Strengths A client enthuses: "The firm provides a first-rate service and the lawyers demonstrate broad knowledge of tax law, remaining on top of every single matter on which they are instructed."

Work highlights Defended Bristol-Myers Squibb against an unfavourable resolution which rejected the company's entitlement to tax deductions relating to promotional expenses.

Significant clients Merck, Bayer, Agroindustrias Unidas de México, Minera Media Luna, Compañía Minera Cuzcatlán.

Notable practitioners

Key partner Sergio Ruiz Lopez is singled out for praise by sources. One client notes: "He is a clear communicator and has the necessary expertise as well as the ability to convey it in an accessible manner, especially to clients that are not experts themselves." Another source enthuses: "I would recommend him due to his responsiveness and familiarity with international tax matters."

Department profile by Goodrich Riquelme y Asociados

Our team provides high level Tax Advisory to support our clients with the design and implementation of “tailor made” strategies to achieve corporate and commercial goals by optimizing their financial resources from a tax perspective within the framework of the legal provisions, including, among others, the analysis of international tax treaties in global operations, corporate reorganizations and restructuring, and the implementation of governance policies.

We also offer advice to our clients in litigation matters by filing the applicable means of defence against actions that violates their taxpayer’s rights such as administrative appeals for reconsideration, nullity procedures and amparo lawsuits.

Our tax department is recognised in the Pharmaceutical Industry as one of the Leader Teams in litigation because of the expertise of more than 30 years, not only in taxation, but in administrative and health specific regulation as well, having trials before the Supreme Court of Justice that have made precedents applicable for the general Industry.

In regard with the Mining sector in Mexico, we manage more than 28 trials per year, advising International Groups in the compliance of Federal and Local legislation.

Finally, having a quite consolidated O&G area, and with the latest energy reform, our Tax department is pioneer in the O&G Taxation in Mexico, advising international companies in the entrance of the private sector to the O&G market in Mexico.

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Jones Day - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Head of department: Rodrigo Gómez Ballina
- 1 partner
- 3 other qualified lawyers

What the team is known for Respected international firm with global reach and a compact team of tax specialists in Mexico. Active in representing clients in administrative litigation cases to appeal unfavourable tax assessments, as well as designing efficient tax structures for corporate transactions such as joint ventures.

Strengths One client states: "What I think is really important is the lawyers' dedication to their clients. I would highlight their consistently fast response times and punctual delivery."

Work highlights Represented the Mexican subsidiary of a major international manufacturer of plumbing fixtures in an appeal against a USD20 million tax assessment handed down by the Mexican tax authorities.

Significant clients Toyota, Lowe's Corporation, The Haskell Company, Essilor Group, Forbes Energy Services.

Notable practitioners

Partner Rodrigo Gómez Ballina has over 15 years of experience in assisting clients with tax planning, regularly advising on matters of international and domestic taxation as well as the tax aspects of transactions. Clients appreciate his "vast knowledge of tax law," and his "ability to defend his position very well."

Department profile by Jones Day

Department profile not yet provided by Jones Day. Please see their firm profile.

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KPMG Cárdenas Dosal, S.C. - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- approximately 16 qualified lawyers

What the team is known for International auditing firm with a strong Mexican offering. Team advises leading corporate names on matters of international taxation and transfer pricing. Fields a group of qualified lawyers and accountants to assist its clients.

Strengths One source notes: "They are judicious, detail-oriented lawyers with profound tax knowledge."

Notable practitioners

Manuel Llaca is the key client contact.

Department profile by KPMG Cárdenas Dosal, S.C.

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Ortiz, Hernandez y Orendain, S.C. - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- approximately 6 qualified lawyers

What the team is known for Tax boutique with a wealth of experience in handling matters spanning the tax and international trade ambits. Recognised for its involvement in complex administrative and constitutional litigation, with additional expertise in transfer pricing.

Strengths One source enthuses: "This is a respectable law firm that handles good cases."

Notable practitioners

Seasoned practitioner Ignacio Orendain Kunhardt is appreciated by peers, who say: "He is well known for litigation as well as local taxation issues." He continues to advise clients on both contentious and consulting mandates.

Senior statesman Luis Ortiz-Hidalgo is lauded by sources for his "unquestionable competence" in tax matters. They go on to say: "He is extremely well recognised in the litigation sphere."

Department profile by Ortiz, Hernandez y Orendain, S.C.

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Santamarina y Steta SC - Tax

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Band 4

第四等

Commentary from the Chambers Latin America guide

Basic facts about the department
- Heads of department: Mariano Calderón and Agustín Gutiérrez
- 1 partner
- 6 other qualified lawyers

What the team is known for Established player in the Mexican market with an experienced tax practice. Tax team frequently interacts with the firm's respected corporate department, advising on the tax implications of transactions, offering further expertise in contentious mandates and international taxation.

Strengths Clients highlight that "Santamarina y Steta as an institution is fantastic; the lawyers have a good understanding not just of the basic principles of taxation, but how they work in practice as well."

Notable practitioners

Clients appreciate partner Mariano Calderón, enthusing: "His forte is contentious cases. His grasp of Mexican laws and those of other countries is excellent, which means that he is able to communicate with foreign clients very well." Peers echo this, pointing to his specialisation in tax litigation.

Senior statesman Agustín Gutiérrez "is a highly recommended tax practitioner," according to clients. He offers many years of experience in tax advice pertaining to corporate and financial transactions at both the local and cross-border levels.

Department profile by Santamarina y Steta SC

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Overview

OVERVIEW OF THE LEGAL TAX PRACTICE IN MEXICO: CHAMBERS LATIN AMERICA 2018

Mexico's legal tax practice has undergone many changes over the last several decades. Years ago, the legal tax practice was dominated by accounting firms which were entrusted with most of the significant tax work in Mexico. Lawyers did not play an important role and, in many cases, were only responsible for assisting accountants in tax controversies. Since only a handful of full-service law firms had significant tax practices, it was not uncommon that law firms relied on accounting firms for transaction-related tax issues.

Today, things are very different. Mexico’s legal tax practices are booming. It is inconceivable to think of a major full-service law firm without a tax practice. Tax lawyers play an important role in day-to-day business transactions and are no longer viewed as ancillary support for accountants. In fact, tax lawyers provide the primary tax advice in many business transactions. Accounting firms have consequently grown their legal tax departments and, together with in-house accountants, provide integrated tax advice to clients.

The relevance of legal tax boutiques in Mexico is ever-increasing. Traditionally, legal tax boutiques in Mexico were only active in representing clients in tax litigation and were not actively involved in other areas. Now, legal tax boutiques provide clients with a wide range of tax services and are no longer viewed exclusively as tax litigators.

Tax litigation in Mexico has also evolved greatly over the past few years. Tax cases were previously litigated in Mexico by arguing failure to comply with formalities in the process by the tax authorities. Amparo lawsuits were also common. An amparo lawsuit challenges the constitutionality of a provision in the tax statute. Historically, most major tax reforms have been challenged by taxpayers through amparo lawsuits, and many times the decisions were favourable to the taxpayers. The consequence was that some taxpayers were exempted from the application of certain provisions of tax statutes until legislative changes were made to eliminate the unconstitutionality of these provisions. As legal tax practices have evolved, so has tax litigation in Mexico. There are still tax cases in which the main arguments are based on flaws in the statutes, but most of the major tax litigation has become very sophisticated. In addition, when challenging the constitutionality of recent tax provisions, the Mexican Supreme Court has frequently ruled against taxpayers.

Consistent with the evolution that tax litigation has had in Mexico, in 2017, amendments to Mexican tax legislation became effective. Therefore two additional instruments are now available, which allow taxpayers to challenge assessments issued by the Mexican Treasury. The first is the administrative appeal exclusively for substantive matters. This new appeal is resolved by the legal section of the Mexican Treasury. The second is the new trial for tax cases that deals exclusively with substantive issues. A new section of the Tax Court was created to resolve this new trial. These two instruments were designed to analyse the real substance of transactions, disregarding arguments about formalities.

The elimination of trade and investment barriers that stemmed from the adoption of the North American Free Trade Agreement, and the fact that Mexico was included as a member of the Organisation for Economic Co-operation and Development, has resulted in the legal tax practice in Mexico transforming from a domestic-oriented practice to a more international practice. Many of the recent tax controversies arising in Mexico have to do with international tax topics, whereas in the past, few Mexican practitioners dealt with international tax issues. Mexico has a network of over 50 international treaties to avoid double taxation, allowing businesses established in Mexico to benefit from the advantages that these treaties bring to international transactions. The Mexican legal tax practice currently has relevant practitioners with sound international tax capabilities that make multinational corporations confident that they will obtain the same sophisticated tax advice in Mexico as they do in other jurisdictions.

For the most part, Mexico has a tax system that is anchored in federal taxes, such as income tax and value-added tax (others include import and export taxes, social security and other excise taxes). The current corporate income tax rate is 30% for entities, and the highest tax rate for individuals is 35%. Additionally, Mexican residents are taxed on their worldwide income. The states levy some minor taxes such as payroll tax, property tax and taxes on hotel accommodations, as well as through co-operation agreements through which they are also entitled to collect federal taxes in certain circumstances. The system is indexed to neutralise the effects of inflation and has undergone several major reforms in recent years.

Foreign investors doing business in Mexico should be aware that, as opposed to many other countries where substance prevails over form, the tax system in Mexico has traditionally been very formalistic. It would be fair to say that the real substance of transactions has not been as relevant as their formalities. However, the system has evolved into one that cares for substance more than before, which is evidenced by the implementation of the new administrative appeal and the new trial that both focus on the real substance of transactions.

The government of President Enrique Peña Nieto promised that an important and significant reform of the Mexican tax system would take place in the second half of 2013, although the reform enacted on 1 January 2014 was considered to have less significant an impact than expected. The following are among the most relevant aspects of the aforementioned reform: (i) the flat tax was eliminated; (ii) the consolidation for tax purposes was eliminated; (iii) the tax on cash deposits was eliminated; (iv) a new tax on dividends of 10% applicable to foreign residents and Mexican individuals was included; (v) the gains from sales of shares through the Mexican stock market are now taxed at a rate of 10%; (vi) the top individual income tax rate was increased from 30 to 35%; and (vii) activities in the border region are now subject to the general 16% rate of VAT (instead of the former preferential 11%) rate.

Mexico had an important energy reform resulting from the December 2013 amendments to the Mexican Constitution that allows the participation of the private sector in the oil and gas market. As part of said reform, on 11 August 2014, the Hydrocarbons Revenue Law was published. Among other things, this new tax law sets forth the rules under which the private sector and the State Productive Companies make payments to the Mexican federal government (conducted through the newly formed Mexican Petroleum Fund) derived from revenues associated with contracts or assignments.

Additionally, in October 2015, rules for the creation of trusts for the investment in energy and infrastructure (the so-called “FIBRA E”) were published. Since then, several tax rules have been released (the latest ones were published on 1 April 2016) to promote and enhance this new investment vehicle that should provide access to private investment primarily in mature cash-generating projects related exclusively to the energy and infrastructure sectors.

Finally, on 1 January 2016, amendments to Mexican tax statutes were enacted to require from multinational corporations the filing of a master information return, local information return and Country-by-Country report on a yearly basis. These new rules resulted from the application of Action Plan 13: Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting of the OECD/G20 Base Erosion and Profit Shifting Project. Qualified multinational corporations are required to make the aforementioned filings for the first time in 2017.

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Senior Statesmen

Enrique Calvo Nicolau

Calvo Nicolau y Márquez Cristerna, S.C.

From the Chambers Latin America guide

Senior statesman Enrique Calvo Nicolau garners plaudits for his years of experience in the tax arena. One peer says: "He is a very respectable lawyer who really stands out in the tax practice area," whilst another enthuses: "He is an institution; he has been around for many years."

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Senior Statesmen

Agustín Gutiérrez

Santamarina y Steta SC

From the Chambers Latin America guide

Senior statesman Agustín Gutiérrez "is a highly recommended tax practitioner," according to clients. He offers many years of experience in tax advice pertaining to corporate and financial transactions at both the local and cross-border levels.

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Senior Statesmen

Luis Ortiz-Hidalgo

Ortiz, Hernandez y Orendain, S.C.

From the Chambers Latin America guide

Senior statesman Luis Ortiz-Hidalgo is lauded by sources for his "unquestionable competence" in tax matters. They go on to say: "He is extremely well recognised in the litigation sphere."

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Senior Statesmen

José Manuel Trueba Fano

Ortiz, Sosa y Asociados S.C.

From the Chambers Latin America guide

Senior statesman José Manuel Trueba Fano of Ortiz, Sosa y Asociados S.C. is lauded by peers as "one of the greatest advisers in Mexico." He continues to provide strategic tax counsel to corporate clients in relation to transactions.

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Band 1

Mauricio Bravo Fortoul

Turanzas, Bravo & Ambrosi

From the Chambers Latin America guide

Leading practitioner Mauricio Bravo Fortoul focuses his practice on tax litigation, and is highly active advising clients from the energy sector. Clients offer their praise of his professional support, stating: "He is a person that speaks with absolute clarity, hence he is able to make his clients understand legal concepts even when they are generally unfamiliar with legal terms. He keeps us informed as to what our options are in any eventuality."

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Band 1

Jorge Covarrubias Bravo

Despacho Parás

From the Chambers Latin America guide

"Unquestionable market leader" Jorge Covarrubias Bravo is widely commended by peers for his role in representing notable names in the Mexican market from key sectors including telecommunications. One peer reports: "He is a strong practitioner in the sense that he represents key clients and is a capable lawyer; for these reasons, I consider him a first-rate professional."

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Band 1

Ramiro González Luna

DLA Piper Gallastegui y Lozano

From the Chambers Latin America guide

Leading individual Ramiro González Luna is highlighted by peers, who commend his consolidated practice. They go on to say: "He is an extraordinary lawyer on the transactional and consulting sides. He has been very successful for many years." One client adds: "I would definitely recommend him for tax matters," adding: "He is a very good tax lawyer with a lot of experience and training in this field."

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Band 1

Jaime González-Béndiksen

BéndiksenLaw

From the Chambers Latin America guide

Arturo Pérez Robles of Pérez Robles Abogados, S.C. is lauded by sources as "a leader in tax matters," with sources highlighting his expertise in both tax litigation and the tax aspects of transactions, particularly M&A deals. One peer goes on to highlight that he is "a top-rate tax lawyer; one of the best that I know."

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Band 1

Gabriel Ortiz Gómez

Ortiz Abogados Tributarios

From the Chambers Latin America guide

Esteemed practitioner Gabriel Ortiz Gómez earns recognition from clients, who state: "Gabriel is extraordinary when it comes to interpreting tax law and representing clients before the SAT." He is highlighted by peers for his many years of experience in the tax field, as well as his level of specialisation in tax litigation.

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Band 1

Arturo Pérez Robles

Pérez Robles Abogados, S.C.

From the Chambers Latin America guide

Respected practitioner Jaime González-Béndiksen of BéndiksenLaw is active across the tax and international trade spaces, offering particular prowess in Mexico's maquiladora programme. He is recognised amongst peers for his expertise in this field.

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Band 1

Enrique Ramírez Figueroa

EY Mexico

From the Chambers Latin America guide

Leading partner Enrique Ramírez Figueroa heads the firm's tax litigation practice. Peers single him out for praise, lauding him as "a great litigator." Market commentators go on to say: "He is one of the few litigation practitioners that really understands business, so he can also do consulting work. His practice is very comprehensive."

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Band 1

Manuel Sáinz Orantes

Chevez, Ruiz, Zamarripa y Cia., S.C.

From the Chambers Latin America guide

Leading figure Manuel Sáinz Orantes is held in high esteem by peers, who credit him with a prestigious presence in the market, adding: "He is a very good lawyer who is highly knowledgeable and respected in the tax field." Sources laud him for his reputation in the tax litigation arena specifically, in which he has over 30 years of experience.

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Band 1

Manuel E, Tron SC

From the Chambers Latin America guide

Sole practitioner and leading figure Manuel Tron is highlighted by sources for his front-running position in the tax field. A client notes: "He is a top-notch lawyer who achieves the best possible situation for his clients." A market commentator goes on to note: "I consider him to be one of the greatest tax practitioners in Mexico." His practice includes tax consulting, international taxation and estate planning.

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Band 2

Mauricio Ambrosi Herrera

Turanzas, Bravo & Ambrosi

From the Chambers Latin America guide

Senior partner Mauricio Ambrosi Herrera is active in matters pertaining to international taxation, particularly transfer pricing. Clients enthuse: "He is a very good lawyer with a lot of experience and great English skills." Sources go on to comment: "He is intelligent, hard-working and reliable; he is also both an adviser and a litigator, which in tax is very helpful."

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Band 2

Anaya Abogados Asociados, S.C.

From the Chambers Latin America guide

Senior partner Edgar Anaya focuses his practice on the tax planning and litigation areas. Clients describe him as "an approachable lawyer who provides practical and forward-thinking solutions to avoid lengthy processes." Sources add: "His approach emphasises responsiveness and providing good support for the legal recommendations that he makes."

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Band 2

Pedro Arias Garrido

Arias, Meurinne y Rodríguez, S.C.

From the Chambers Latin America guide

Pedro Arias Garrido is singled out by sources for his activity and expertise in the administrative litigation space, both within the tax sphere and beyond. Peers say: "He is a good lawyer, a tough litigator and someone who does things properly." One market commentator goes on to mention: "I would recommend him to my own clients."

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Band 2

Alejandro Barrera Fernández

Basham, Ringe y Correa S.C.

From the Chambers Latin America guide

Well-known practitioner Alejandro Barrera Fernández is lauded by peers as "outstanding in tax issues; when you ask him for anything, he always adds value." Sources also highlight his professionalism. He leads the firm's tax consulting practice and advises both corporations and individuals.

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Band 2

Luis Gerardo Del Valle Torres

Jáuregui y Del Valle, S.C.

From the Chambers Latin America guide

Key partner Luis Gerardo Del Valle Torres receives endorsements from clients, who say: "He has really earned our trust because he knows his clients and is a highly effective lawyer. We really appreciate the opportunity to work with him." They go on to comment: "What comes to mind about him is his complete professionalism and profound knowledge of both national and international tax and legal concepts."

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Band 2

Ricardo León Santacruz

Sánchez DeVanny Eseverri, S.C.

From the Chambers Latin America guide

Partner Ricardo León Santacruz focuses his practice on the fiscal impact of corporate transactions, advising on efficient tax structures for M&A deals, as well as tax restructurings. He remains an active figure in the transfer pricing field. Clients appreciate his advice, stating: "He is very well versed in Mexican and cross-border tax matters and explains tax law extremely well." Sources add: "He is a truly distinguished tax practitioner."

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Band 2

Natera, S.C.

From the Chambers Latin America guide

Key partner Christian Natera is highlighted by peers for his technical expertise in tax issues. They say: "He has a strong client base and was also trained as an accountant, which means that technically speaking he is very capable." He advises on a range of tax issues including inbound investment, litigation and transfer pricing.

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Band 2

Basham, Ringe y Correa S.C.

From the Chambers Latin America guide

Gerardo Nieto leads the firm's tax litigation practice, focusing on contentious tax work such as administrative and constitutional litigation proceedings. Peers say: "He is a good tax litigator and is devoted to his clients." He offers further expertise in tax audits, restructurings and planning.

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Band 2

Eduardo Revilla Martínez

Deloitte Legal Services

From the Chambers Latin America guide

Eduardo Revilla Martínez is highlighted by peers for his specialisation in tax matters. Sources say: "He is very present in the tax area." He is active in a range of mandates, among which tax litigation features prominently. He is also recognised as a frequent contributor to notable publications regarding tax law in Mexico.

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Band 2

Alejandro Torres Rivero

Chevez, Ruiz, Zamarripa y Cia., S.C.

From the Chambers Latin America guide

Partner Alejandro Torres Rivero is deemed by market sources to be highly specialised in the field of tax litigation, with a particular focus on amparo proceedings. Peers laud him as "a great litigator."

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Band 3

Roberto Arena Reyes Retana

Gardere, Arena y Asociados, S.C.

From the Chambers Latin America guide

Clients are full of praise for partner Roberto Arena Reyes Retana. They say: "He is a highly sophisticated, respected and experienced lawyer. His financial knowledge makes his tax advice stand out, whilst in terms of strategic decision making, he also provides highly valuable suggestions." Sources go on to add: "He always contributes creative ideas and is very helpful as counsel due to his experience."

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Band 3

Alejandro Calderón Aguilera

Calderón, González y Carvajal, S.C.

From the Chambers Latin America guide

A source notes that Alejandro Calderón Aguilera "is extremely active in the tax space," with another peer lauding him as "a dedicated lawyer, for whom I have a lot of respect." He offers expertise of Mexican tax legislation, as well as its Anglo-Saxon counterpart, advising clients on matters pertaining to double taxation and transfer pricing.

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Band 3

Fernando Camarena Cardona

Gardere, Arena y Asociados, S.C.

From the Chambers Latin America guide

Partner Fernando Camarena Cardona is singled out for praise by clients, who state: "He is a great lawyer who always shows an understanding of our business as a whole, not simply the question at hand; this makes him a great tax lawyer but also a notable business adviser for our company. He always goes beyond simply resolving queries, seeking real solutions to our problems."

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Band 3

Luis C Carbajo-Martínez

Baker McKenzie

From the Chambers Latin America guide

Clients credit department head Luis Carbajo-Martínez with "ample experience in tax matters," adding: "He is also knowledgeable about maquiladora and customs issues, which complements his tax knowledge well." Peers describe him as "someone who really contributes to discussions, with distinctive expertise in tax issues relating to hydrocarbons."

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Band 3

Ricardo Cervantes

Chevez, Ruiz, Zamarripa y Cia., S.C.

From the Chambers Latin America guide

Ricardo Cervantes receives praise from clients, who state: "He has a skill that we appreciate, which is to always play devil's advocate and put himself in the position of the regulator; this ensures that we have a robust argument."

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Band 3

José Miguel Erreguerena Albaitero

Rizo, Erreguerena y Garza Cantú S.C.

From the Chambers Latin America guide

Partner José Miguel Erreguerena Albaitero of Rizo, Erreguerena y Garza Cantú S.C. "clearly understands the law in this area, is very reliable and has a comprehensive tax practice," according to one source. He is also highlighted for his many years of experience in the tax field.

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Band 3

Ramírez, Gutiérrez-Azpe, Rodríguez-Rivero y Hurtado S.C.

From the Chambers Latin America guide

Rosario Huet of Ramírez, Gutiérrez-Azpe, Rodríguez-Rivero y Hurtado S.C. offers expertise in both tax litigation and matters of international taxation, advising both domestic and international clients. Peers appreciate her years of experience in the field.

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Band 3

Turanzas, Bravo & Ambrosi

From the Chambers Latin America guide

Partner Carl Koller is singled out for praise by clients, who describe him as "someone who provides a quick and effective response," adding: "He is very client-oriented and pragmatic." Peers highlight that "he is a real professional," also making reference to his technical expertise.

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Band 3

Luis Roberto Lara Ramos

Lara & Medina, S.C.

From the Chambers Latin America guide

Founding partner Luis Roberto Lara Ramos of Lara & Medina, S.C. is active across the professional and academic spaces. One peer enthuses: "He is a very good lawyer from a technical perspective; there is no question of his competence."

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Band 3

Eduardo Méndez Vital

PricewaterhouseCoopers (PwC) México

From the Chambers Latin America guide

The "very well-respected" Eduardo Méndez Vital garners endorsements from peers for his experience in the field of tax litigation.

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Band 3

Arias, Meurinne y Rodríguez, S.C.

From the Chambers Latin America guide

Luis Meurinne focuses his practice on tax consulting and planning, leading the firm's endeavours in both of these areas. He has also made a number of relevant academic contributions to the Mexican tax space.

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Band 3

Reginaldo Montaño Rodríguez

RMR Abogados

From the Chambers Latin America guide

Founding partner Reginaldo Montaño Rodríguez of RMR Abogados is highlighted by sources as "a technically gifted litigator." He is active in both tax litigation and consulting, with peers also praising his transactional expertise.

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Band 3

EY Mexico

From the Chambers Latin America guide

Partner Nora Morales receives ample praise from peers. They highlight her as "a jewel of the practice," and enthuse: "She is amazingly intelligent and a great lawyer." Sources add: "She works as both a litigator and an adviser and is very good at rendering tax advice."

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Band 3

Von Wobeser y Sierra, SC

From the Chambers Latin America guide

Fernando Moreno of Von Wobeser y Sierra, SC heads the firm's tax department. Sources credit him with "vast experience in corporate and tax matters," adding: "He is a specialist in counselling clients on efficient tax planning strategies."

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Band 3

Jorge Narváez-Hasfura

Baker McKenzie

From the Chambers Latin America guide

Partner Jorge Narváez-Hasfura is highly regarded by clients, who state: "He is a very experienced partner who manages client relationships very well. He instils trust in his clients." His practice centres on issues relating to corporate taxation, transfer pricing and tax restructurings.

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Band 3

Ignacio Orendain Kunhardt

Ortiz, Hernandez y Orendain, S.C.

From the Chambers Latin America guide

Seasoned practitioner Ignacio Orendain Kunhardt is appreciated by peers, who say: "He is well known for litigation as well as local taxation issues." He continues to advise clients on both contentious and consulting mandates.

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Band 3

Gabriela Pellón Martínez

Galicia Abogados, S.C.

From the Chambers Latin America guide

Sources highlight Gabriela Pellón Martínez's recent move to Galicia Abogados, saying: "She is very knowledgeable and is going to do very well at her new firm." She earns plaudits for her expertise in tax litigation.

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Band 3

Pedro Ramírez Mota Velasco

Turanzas, Bravo & Ambrosi

From the Chambers Latin America guide

Pedro Ramírez Mota Velasco is involved in the firm's most complex matters within the field of estate planning. Clients also highlight him for his activity in international matters, saying: "He is very intelligent and an expert in international taxation. He is a first-rate lawyer."

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Band 3

Jorge San Martin Elizondo

SMPS Legal

From the Chambers Latin America guide

Partner Jorge San Martin Elizondo is highly specialised in mandates requiring knowledge of tax structures for inbound investment, advising on M&A transactions, tax restructurings for existing companies and international taxation. A client enthuses: "He quickly understands the relevant issues at hand to develop creative solutions."

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Band 3

Alejandro Santoyo

Creel, García-Cuéllar, Aiza y Enríquez, S.C.

From the Chambers Latin America guide

Clients are full of praise for practice leader Alejandro Santoyo, whom they describe as "client-focused, very knowledgeable and responsive." Sources highlight his level of specialisation, saying: "He is good at advising on the tax aspects of capital markets deals and has a lot of experience in this field. He also understands how the tax system works so if you put those two things together, you get a really good final product."

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Band 3

Adalberto Valadez Hernández

Nader, Hayaux y Goebel, S.C.

From the Chambers Latin America guide

Sources highlight practice head Adalberto Valadez Hernández of Nader, Hayaux y Goebel, S.C., enthusing: "He is very pleasant to work with, and also very firm and knowledgeable of his area. What is invaluable to us is that he knows the regulation that affects our business from his past experience."

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Band 3

Gil Zenteno Garcia

Basham, Ringe y Correa S.C.

From the Chambers Latin America guide

Partner Gil Zenteno Garcia has 25 years of experience in tax issues. He focuses his practice on contentious tax mandates, including amparo proceedings. Peers describe him as "a tough litigator." Peers also highlight his experience and activity in matters concerning international trade.

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Band 4

Guillermo Aguayo Garza

White & Case SC

From the Chambers Latin America guide

Partner Guillermo Aguayo Garza of White & Case SC comes highly recommended by clients, who say: "In the technical sense, he is very knowledgeable of matters that tax lawyers do not always know about, like transfer pricing. He is also very professional and accessible."

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Band 4

Mariano Calderón

Santamarina y Steta SC

From the Chambers Latin America guide

Clients appreciate partner Mariano Calderón, enthusing: "His forte is contentious cases. His grasp of Mexican laws and those of other countries is excellent, which means that he is able to communicate with foreign clients very well." Peers echo this, pointing to his specialisation in tax litigation.

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Band 4

Sandro Castañeda

PricewaterhouseCoopers (PwC) México

From the Chambers Latin America guide

Partner Sandro Castañeda is described by a peer as "a relevant player involved in large cases." He handles litigation and international tax treaty interpretation.

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Band 4

Baker McKenzie

From the Chambers Latin America guide

Ulises Castilla has experience in both the public and private sectors, having spent time working at the Mexican tax authorities. His practice focuses on tax litigation and strategic consulting. Peers report: "He is definitely one of the strongest lawyers that the firm has at present."

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Band 4

Garrigues

From the Chambers Latin America guide

Key partner Santiago Chacón of Garrigues receives endorsements from clients, who state: "He is someone that will listen to you and then provide you with a solution to your problem." Another source notes: "I would highlight his ability to communicate legal concepts - that really stands out."

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Band 4

Jorge Correa Cervera

Creel, García-Cuéllar, Aiza y Enríquez, S.C.

From the Chambers Latin America guide

Jorge Correa Cervera enters the rankings after receiving praise from sources. One interviewee comments: "He is really responsive, which I think is an underrated attribute in lawyers. He is very intelligent when handling clients; he provides all the right information without overloading us with details."

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Band 4

Rodrigo Gómez Ballina

Jones Day

From the Chambers Latin America guide

Partner Rodrigo Gómez Ballina has over 15 years of experience in assisting clients with tax planning, regularly advising on matters of international and domestic taxation as well as the tax aspects of transactions. Clients appreciate his "vast knowledge of tax law," and his "ability to defend his position very well."

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Band 4

Juan Carlos Izaza

Izaza Abogados

From the Chambers Latin America guide

Juan Carlos Izaza of Izaza Abogados is recognised by peers for his many years of practice. They go on to say: "He is someone who always contributes ideas."

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Band 4

Jorge A Jiménez Cañizares

Deloitte Legal Services

From the Chambers Latin America guide

Partner Jorge Jiménez Cañizares receives praise for his knowledge of tax issues affecting the insurance sector, as well as the financial services arena in general. He specialises in consulting and tax litigation matters.

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Band 4

Haynes and Boone, SC

From the Chambers Latin America guide

Edgar Klee of Haynes and Boone, SC is highlighted for his involvement in both tax and customs matters. Peers reference his strong technical knowledge and his presence in this field.

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Band 4

Calvo Nicolau y Márquez Cristerna, S.C.

From the Chambers Latin America guide

Partner Oscar Marquez is qualified as both a lawyer and an accountant. He mainly advises on contentious matters such as administrative litigation before the Mexican tax authorities. Peers note his involvement in representing individuals.

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Band 4

Abel Francisco Mejía Cosenza

Sánchez-Devanny Eseverri, S.C

From the Chambers Latin America guide

Clients say that Abel Francisco Mejía Cosenza "is able to work with clients of all profiles, including the more demanding ones; he knows how to work with different personalities and provides good answers to our questions." He advises ultra high net worth individuals on estate planning and restructurings, as well as corporations on the tax aspects of cross-border transactions.

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Band 4

Ana Paula Pardo Lelo de Larrea

SMPS Legal

From the Chambers Latin America guide

Ana Paula Pardo Lelo de Larrea advises both corporations and individuals on the tax aspects of corporate transactions. Her expertise spans transfer pricing, tax restructuring and tax planning. Clients commend her English language skills and international experience, adding: "She is an amazing adviser who was able to solve all our problems and doubts."

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Band 4

EY Mexico

From the Chambers Latin America guide

José Pizarro enters the rankings after attracting strong praise from sources, who state: "He is a great lawyer. You can ask him anything and he has an opinion. He is one of the reasons the firm is doing well." 

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Band 4

Javier Portas Ledesma

Creel Abogados

From the Chambers Latin America guide

A source enthuses that Javier Portas Ledesma "is a great professional with excellent legal knowledge. He proposes creative legal solutions and is always present throughout the duration of the matter." He frequently advises on mandates concerning international taxation.

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Band 4

Sergio Ruiz Lopez

Goodrich Riquelme y Asociados

From the Chambers Latin America guide

Key partner Sergio Ruiz Lopez is singled out for praise by sources. One client notes: "He is a clear communicator and has the necessary expertise as well as the ability to convey it in an accessible manner, especially to clients that are not experts themselves." Another source enthuses: "I would recommend him due to his responsiveness and familiarity with international tax matters."

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Band 4

Rafael Tena Castro

Acedo Santamarina, S.C.

From the Chambers Latin America guide

Partner Rafael Tena Castro of Acedo Santamarina, S.C. "is my go-to lawyer for all tax matters" according to one source. Another adds: "He is a detail-oriented lawyer who likes to get down to the detail of a matter without taking a one-way approach." He is active in both tax advisory and litigation.

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Band 4

Sergio Arturo Tiburcio Tiburcio

Hogan Lovells

From the Chambers Latin America guide

One source enthuses that partner Sergio Arturo Tiburcio Tiburcio of Hogan Lovells BSTL "is a very respected practitioner in the Mexican market." Market commentators go on to state: "He has a lot of experience in the tax field and is professional in every sense."

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Band 4

Angel J. Turanzas Díaz

Turanzas, Bravo & Ambrosi

From the Chambers Latin America guide

Angel Turanzas Díaz offers expertise in matters relating to both corporate and individual taxation. He represents clients from a range of sectors including energy and transportation. Clients describe him as "an intelligent and talented lawyer."

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Band 4

Guillermo Villaseñor Tadeo

Sánchez DeVanny Eseverri, S.C.

From the Chambers Latin America guide

Partner Guillermo Villaseñor Tadeo is active across the transfer pricing and litigation fields, handling contentious mandates against the Mexican tax authorities on behalf of multinational clients, as well as tax audits. Clients single him out for praise, saying: "You can discuss anything with Guillermo, and if he isn't an expert in that particular area, he can refer you to someone who is."

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Band 4

Creel, García-Cuéllar, Aiza y Enríquez, S.C.

From the Chambers Latin America guide

Partner Omar Zúñiga is recognised for his experience spent as both external and in-house counsel. Clients highlight his drafting skills, stating: "When we receive documents from him, they are excellent and never burdensome to read. He has a real understanding of Mexican law outside of the tax area as well."

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Up and Coming

Anaya Abogados Asociados, S.C.

From the Chambers Latin America guide

Fabiola Díaz leads the firm's tax consulting group, advising both individuals and corporations. Clients appreciate her support, as one interviewee points out: "I think she has wide knowledge across the tax and legal spheres; she has great analytical skills and constantly seeks alternatives and solutions."

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Up and Coming

Mariana Eguiarte Morett

Sánchez DeVanny Eseverri, S.C.

From the Chambers Latin America guide

Up-and-coming individual Mariana Eguiarte Morett receives recognition from sources, who enthuse: "She is solid from a technical perspective, bilingual, and has a lot of experience in global tax matters. She is also always available." Her practice centres on issues of corporate taxation.

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Associates to watch

Patricia Lopez Padilla

Natera, S.C.

From the Chambers Latin America guide

Patricia Lopez Padilla gains praise from peers for her visibility in the tax field. She focuses her practice on tax litigation.

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Associates to watch

Federico Scheffler

SMPS Legal

From the Chambers Latin America guide

Associate-to-watch Federico Scheffler receives praise from sources, with clients particularly highlighting his rapid response times. He focuses on tax planning and tax structures for M&A transactions.

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