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  1. Peru – Leading tax law firms
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Peru - TDH500

  1. 1
    • Luis Hernández - Hernández & Cía. Abogados
    • Humberto Medrano - Rodrigo, Elías & Medrano, Abogados
    • Fernando Zuzunaga - Zuzunaga, Assereto & Zegarra Abogados

Long known for its ‘legal solidity and its ability to win difficult cases’, Hernández & Cía. Abogados fields a ‘highly reputed’ 14-strong team under the direction of Luis Hernández, ‘a monumental figure’ (who is ‘not retired by any means’ according to one peer who currently has him as a counterpart). The practice advises on tax compliance and planning, private and adminsitrative audits, transactional tax matters and tax litigation, as well as customs and international trade law. Hernández is flanked by key partners Leonardo López and Milagros Bustillos who are particularly active in the oil-and-gas, mining, commodities and telecommunications sectors, regarding both consultative and contentious matters. The trio also handles VAT fiscal credits, tax audits, tax analysis and tax structuring. Recent matters saw the team acting in financially significant proceedings against SUNAT income tax assessments on behalf of major multinationals, particularly in the mining sector; assist clients with the tax analysis, planning and structuring of transactions; and handling all the tax aspects of both parties in a major merger in a regulated sector. One public deal saw Leonardo López lead advice to investment fund Faro Capital on its acquisition of the textile-related assets of Barache and FF Textil. Day-to-day matters include the practice acting as permanent tax counsel to an impressive corporate client base including Perupetro, Grupo Telefónica, Procter & Gamble, Petrex, Saga Falabella and Interbank. Senior associates Gonzálo Echevarría, Roxana Terrones and Patricia Tamashiro are also noted.

Rodrigo, Elías & Medrano, Abogados’ 20-strong, eight-partner practice is led by Alex Córdova and handles the full range of tax-related matters, including corporate tax strategy, indirect taxes, the taxation of individuals, employee benefits, transfer pricing, tax audits and contentious proceedings. Headline work includes advice to Tahoe Resources regarding its $1.1bn acquisition of Rio Alto Canada (the owner of mining projects and hydropower generators in Peru), under a preferential 5% income tax rate for non-domiciled vendors. Córdova won a precedent-setting decision before SUNAT and the Tax Court when representing BHL Peru with regard to the the incorporation of foreign trade operations in the company’s VAT taxable base, successfully establishing that they could so be included. Córdova teamed up with founding partner Humberto Medrano to represent Savia Perú in a complex VAT refund case (valued at $700m), which is currently pending a Supreme Court decision; and also works alongside Gonzalo La Torre to provide ongoing advice to MinMetals Group in the wake of its acquisition of Las Bambas copper project. Fiscal planning specialist Tulio Tartarini, who also represents clients in contentious tax matters, successfully advised BCTS Consulting on the overturning of a supposed VAT liability; and Raúl Hidalgo advised Transmisora Eléctrica del Sur on its entry into an investor’s agreement with the Peruvian state so as to benefit from a VAT early-recovery regime for a transmission line project. Alex Morris is also noted, and other matters include advising clients before the judiciary with regard to tax stability agreements. The group was bolstered further with the promotion of Raúl Hidalgo to the partnership; the hires of associate José Diego Ruiz Huidobro and senior associate Vivian Burga (from Estudio Echecopar member firm of Baker & McKenzie International and EY, respectively), as well as the incorporation as juniors of two former interns; but saw the departures of former counsel Silvia Muñoz Salgado (who left for tax boutique Gálvez y Dolorier Abogados), Silvia León and Lorena Barrenechea. As we go to press, the firm has announced significant further reinforcement at the department with the hires of international tax specialist Gustavo Lazo (from Estudio Olaechea) and transactional tax specialist Jose Talledo (from Estudio Echecopar); as well as associates Jorge Moreno and Joan Tello from PWC and EY, respectively. Clients include Bolsa de Valores de Lima, Southern Peru Copper, San Fernando, Banco Continental and Corporación Lindley. José Chiarella joined Garrigues in 2016.

Estudio Echecopar member firm of Baker & McKenzie International has ‘solid capability in complex tax matters’, which, with the early-2016 arrival of Martha Morales from Baker & McKenzie S.A.S.’s Monterrey office, now includes significant in-house transfer pricing capacity. Clients highlight ‘good service’ and ‘opportune and integrated responses that provde a 360° vision of risks, contingencies and possible solutions’. With ‘a strong grasp of the tax landscape’, Rolando Ramírez-Gastón directs a ten-strong team of ‘highly qualified and experienced professionals’. The pracice has particular expertise in the banking, healthcare, retail, agribusiness, mining, energy and oil-and-gas industries and is best known for its transactional tax work – although it also has profile and a good track record in contentious matters. Its recent workload has involved considerable tax planning analysis, strategy and structures in relation to scenarios including the division of business lines and business transferrals, as well as VAT and witholding income tax work. The team has also been involved in arbitration regarding a tax stability agreements and recently advised new client Bancolombia on matters involving transfer pricing. Partner José Talledo’s advisory practice has a strong tax planning component, and he, like Ramírez-Gastón, also represents clients in administrative and judicial tax controversies. Key support comes from principal associate Carla Peirano, (formerly at Repsol, she has particular expertise in the oil-and-gas sector); and senior associate Erick Lind who specializes in wealth planning and CFC regulations above and beyond his general tax practice. Other clients include Aseguradora Magallanes, American Tower and Queiroz Galvao Oil & Gas. As we go to press, Talledo has announced his departure from Rodrigo, Elias & Medrono Abogados.

TAXAND member Miranda & Amado fields an eight-strong tax group that handles tax advisory, tax planning, advisory matters and litigation, and has particular expertise in the oil-and-gas, electricity, telecoms and infrastructure sectors. ‘Quietly effective’ practice head Rocío Liu has over 20 years’ experience and is particularly knowledgeable with regard to the regulated industries; she is currently president of the tax committee of investment agency Procapitales. Liu’s recent mandates include headline work advising Citibank Perú on the tax structure and tax planning for the $295m sale of its retail and commercial banking operations to Scotiabank; as well as representing Laureate Education subsidiaries UPC and UPN in a constitutional amparo regarding the unconstitutionality of a law limiting a profit-reinvestment tax regime in the educational sector; and advising Talma Servicios Aeroportuarios in a tax appeal against a SUNAT declaration of the company’s joint-liability for a third party’s tax debts. Young partner Pablo Sotomayor recently advised Traxys del Perú on a successful $1.8m VAT refund application, the first time SUNAT has made such a refund when the miscalculation of limits was due to the claimant. Other matters include advising clients -such as Edelnor, Chinango ABL Pharma and Natura Cosmeticos- with regard to income tax, excise tax and VAT assessments made by SUNAT; avoiding double taxation in multijurisdictional acquisitions; and infrastructure project-related tax issues. Key support comes from senior associates Vanessa Masalías (who focuses on international tax, tax planning and customs law), and Luis Miguel Sánchez (international tax, tax planning and tax compliance); however, Johana Timana left for Philippi Prietocarrizosa Ferrero DU & Uria in September 2015. Clients include BTG Pactual Bank, Productos Roche Q F, Trafigura, Cementos Pacasmayo, Enersur and Cia de Seguridad Prosegur.

Operating at a first class level’, Muñiz, Ramírez, Pérez-Taiman & Olaya Abogados’ tax practice now numbers 18 lawyers, including –with the recent promotion of Luis García– six partners. The team works across the full spectrum of tax matters but is particularly strong on tax planning (where both senior partners have noteworthy practices) and transactional tax matters. It has also developed a strong wealth management practice over the last four years (still a relatively novel offering in the Peruvian market), and has a speciaist compliance sub-team. Practice head Fernando Castro is a ‘highly active’ tax planning specialist who frequently advises key clients such as PepsiCo, Mitsubishi, Nestlé, Pfizer and Colgate-Palmolive. Now a senior partner, the ‘valuable’ Jorge Otoya ‘stands out for his experience’; specialised in tax planning, he has a strong focus on transactional matters but also handles financial tax, private clients work and litigation. Otoya recently led advise to Graña y Montero regarding the structure for its acquisition of a 44% stake in Adexus Chile and the subsequent integration of both parties businesses in Peru and Chile); and Scotiabank, as arranger, regarding Redesur and Tesur’s $110m joint bond issuance via an SPV and its securitisation. The team also handled the tax aspects of other transactional matters including Votrantim-Metais’ acquisitionof 10% of Minera Milpo via a tender offer; Arca Continental’s acquisition of a majority stake in Corporación Lindley; and Lipesa’s sale of its businesses in four regional jurisdictions to Chem Treat. On the litigious side the team has been active in a leading case with ten separate legal processes on behalf of Telefónica del Perú, which is challenging a number of Tax Court resolutions; the amount involved in the disputes exceeds $2bn. Other key figures include Guillermo Ruiz and Karin Orbezo, who both focus primarily on tax consultancy; Daniel Ono who undertakes both tax consultancy and litigation; and senior associate Frezzia Saavedra, who leads the tax compliance sub-team. Other clients include Abbott Laboratories, Credit Suisse, Robert Bosch and Compañía Latinoamericana de Radiodifusión.

The ‘sizeable and important’ tax department at Philippi Prietocarrizosa Ferrero DU & Uria number 20 lawyers and is divided into three sub-groups: international taxation, tax litigation, and general tax consulting. The division reflects the degree of specilisation in the practice which has a strong track record for contentious matters (both at the tax court and before the judiciary), extensive transactional and planning capability, and which continues to deepen its international tax capabilities. Practice head Walker Villanueva is a ‘very good professional’ and can be credited with the development of the practice. He recently acted in conjunction with senior associate Sandra Rivas to advise Grupo Telefónica in a $25m matter related to Peru’s VAT rebate refund regime; and the pair also teamed up to advise Scotiabank during a tax audit by the Peruvian Tax Authority regarding the financial institution’s tax obligations, particularly income tax withholdings and labour taxes. Other key activity saw Dante Sanguinetti, who is highlighted by clients, and associate Mery Alvarado advise The Carlyle Group on the $66m purchase of Condor Travel (its Chilean subsidiary) and Nuevo Mundo Viajes. Partner Ricardo Harten is also active in the sector and the practice group has a strong second line of six senior associates, including Johana Timana who joined from Miranda & Amado in September 2015. Associate Carlos Socola joined from SUNAT the following month. Other key clients include Banco de Crédito del Perú, Ripley, Scotiabank and Grupo Brescia.

Providing ‘personalised attention, true team work and deep analysis’, boutique firm Zuzunaga, Assereto & Zegarra Abogados fields a 26-strong team of ‘excellent professionals’ that includes seven partners. The firm focuses on assisting local and international clients on tax litigation, corporate tax planning and international taxation, as well as on foreign trade and customs matters. Fernando Zuzunaga has a market-wide reputation and is extremely well-regarded by peers and clients alike, while his fellow name partners Juan José Assereto (who focuses on foreign trade and customs) and Juan Carlos Zegarra are highlighted by clients for their timeliness, ‘minute attention to detail and sharp analysis’. Also with the firm since its founding, Luciana Yañez and Sergio Vega León were promoted to partner in January 2016. The firm has a very strong profile in the mining sector (Zuzunaga is president of the SNMPE) and is also active in the electicity sector with clients such a Edelenor and Kallpa. Zegarra has particular expertise in tax planning for the energy and natural resources sector and recently represented Compañia Minera Zafranal in a $20m matter related to the firm’s exploration investment agreement (as well as on issues concerning the definitive VAT recovery regime). Zuzunaga, working in tandem with Lorgio Moreno, head of the firm’s tax defence department, provides ongoing tax-efficiency advice to drilling-services provider Boart Longyear regarding its operations in Peru, including contracts and hedge agreements. The team also advises across a variety of other, primarily domestic tax matters, such as risk evaluation, tax audits, designing transactional tax structures and handling disputes filed before the SUNAT. In addition to the above promotions, Claudia Suárez arrived at the firm as a partner in December 2015 after eight years as tax director of Endesa/Enel; she focuses on tax planning and international taxation. Also noted is international tax focused senior associate Renée Villagra. Additionally, the team was strengtened at the junior level with the hire of Rossana Alarcon. Clients include Minera Barrick, Rio Tinto Peru, Glencore, Siemens and Río Tinto.

The 25-strong tax and labour boutique Gálvez y Dolorier Abogadospunches above its weight’ and is ‘gaining prominence’, not least with a realunch in early 2016 and the boosting of its tax capabilities with the incorporation of former Rodrigo, Elías & Medrano, Abogados counsel Silvia Muñoz Salgado –who focuses on the tax aspects of financial markets/transactions and on international operations– as partner. With her came mid-level associate Martín Tremolada, and the firm also incorporated a further junior, Paul Nina, who focuses on international taxation and transfer pricing, from EY. The firm stands out for its development of defence and litigious strategies regarding audits, and contentious administrative and judicial tax matters, including those relating to transfer pricing and international operations. Other areas of strength include corporate tax planning consultancy, finance-related tax matters and estate planning. The core of the team comprises ‘impressive’ departmental head José Gálvez, who has a strong administrative side to his practice; Karinna Arbulú, whose practice focuses on tax and customs, and Martín Mantilla Hidalgo, who can draw on over 15 years’ experience at SUNAT. The practice can also call on its own group of in house accountants. Clients include Thyssen Krupp, BCO, DHL, Lindley, Los Portales, UPACA, Petroperu, ALAFAL, Grupo Ortiz, Obrainsa, Cofide and Huawei.

Grau Abogados’ tax team possesses ‘ample knowledge of the current regulations and always advises clients when new rules are issued or old ones are modified’. The eight strong practice is co-led by César Castro, who specializes in the tax aspects of M&A, foreign investment and the oil-and-gas sector; and Rolando Cevasco, who focuses on tax planning, audits and contentious tax matters; he has particular expertise in the electricity and mining sectors and also in relation to operations involving non-domiciled entities; ‘his strength is his ability to identify and take on board the nature of the problem presented to him’, commented one client. Recent matters include assisting Chile’s Colbún with the due diligence report (from a tax perspective) of its acquisition of Fénix Power Perú. Other matters include extensive transaction-related tax activity, particularly the origination of tax strucutres, tax advisory, matters related to to tax audits and stability agreements, and defence of contentious claims. Clients include Glencore-Xstrata, Grupo Falabella, Enel Green Power Perú, and Copa Airlines.

Celebrating 20 years in the market, Payet, Rey, Cauvi, Pérez Abogados fields a nine-strong practice co-directed by Ivan Chu and Juan Manuel Salazar. The pair have complimentary practices with Chu primarily dedicated to transactional tax matters along with corporate reorganizations, tax planning, international tax and wealth management; and Salazar also undertaking transactional work but focusing primarily on tax litigation, compliance and consulting. The team offers three primary lines of service, including tax consultancy (planning & tax opinions), tax audit assignments (tax due diligence, tax assessment review, contingency analysis) and litigation (both administrative and judicial); it also has extensive experience in all aspects of tax transactional work. Recent matters saw Chu lead advice to Scotiabank Perú on the structuring of its $295m acquisition of Citibank Perú’s retail and commercial banking operations; and Salazar assist one of the selling shareholders of Condor Travel in relation to a tax contingency revealed by the due diligence process. The pair also teamed up to advise Canada Pension Plan Investment Borad on its indirect purchase of a 7.99% stake in Transportadora de Gas del Peru. Other work includes advising Grupo Credicorp on the tax aspects of the integration of Financiera Edyficar and Mibanco; Scotiabank in relation to notes issues; and Red Eléctrica del Sur on the securitizing of a trust in a transaction with particular tax requirements. The team has also been active on litigation in relation to VAT issues in the hydrocarbons sector. Key suport comes from senior associates Javier Barrios and Andrea Tejeda who both undertake transactional tax and wealth management. Since publication, the team has been further strengthened with the hire of Vanessa Watanabe as counsel; she has experience both in house and in private practice.

Rubio Leguía Normand’s 10 strong tax department is directed by the ‘very capable and insightful’ Marilú Pedraza in conjunction with Cesar Luna. Attending a mixed domestic and international client roster across the full range of tax legal matters, the practice traditionally has particular strength in the energy (Odebrecht Energia, Hunt Oil and ENDESA), mining (Anglo-American and Newmont), telecommunications (Huawei and Torres Unidas) and finance (Morgan Stanley and BNP Paribas) sectors. Past work has seen the team especially active in the tax aspects of major infrastructure projects, advising Consortium Nuevo Metro de Lima, for example, on tax planning related to the construction of the $5.7bn Metro de Lima Linea 2 project; and Odebrecht Latin Invest on financing aspects of the Gasoducto Sur Peruano project. Other key figures include counsel Gilberto Ramos, and key associates Karen Temoche and Kelly Pérez; the team can also call on senior partner Alfonso Rubio.

The small tax practice at Garrigues has developed a healthily mixed caseload in its two years of operation, dealing with day-to-day matters ranging from compliance, tax claims and consultancy; through tax planning, both local and cross-border; to transactional tax matters and structuring. It has particular expertise in concession-related tax matters and, most notably, is currently advising on all the tax aspects of the Metro de Lima Línea 2 project. The small team is led by principal associate Luis Valle, who has approching 20 years’ experience accumulated both in private practice (notably Hernández & Cía. Abogados) and at major consultancies, as well as in house at entities such as EDENOR. Recent matters include assisting Asociación para el Progreso de la Dirección (APD) gain recongnition by the tax authorities as a not-for-profit organization; tax planning and advisory to Sociedad Aeroportuaria Kuntuwarsi in relation to the development of Cusco international airport; and on the transactional front, advising Grupo GTD on the tax aspects of its aquisition of 70% of Grupo Romero’s telecoms corporation Wigo. Key support comes from senior associate Rafael Martinelli, also ex-Hernández & Cía. Abogados. Other matters include advising Deutsche Bank on analysis of the tax implications of a new business line related to the acquisition of receivables, and associated tax planning. Clients include Southern Bridge Capital, Banco de Sabadell, Latin American Power and Credit Agricole. José Chiarella joined the firm in August 2016 from Rodrigo, Elias & Medrano Abogados

Estudio Olaechea provides ‘prompt and concise advice’ and clients are ‘very satisfied with their working relationship’ with the team, its ‘top quality service’ and ‘solid knowledge’. Practice head Gustavo Lazo, who is both a lawyer and an accountant, has approaching 20 years’ experience; he leads a compact, five-strong team that advises across the full range of tax work, from tax advisory and planning to contentious matters. Recent mandates include tax advisory and planning and a consequent corporate restructuring to obtain efficiencies, complex tax-related fund matters, double taxation and income tax exemption, challenges to custom authority valuations; transfer pricing technical report analysis, and the tax planning of a regional business restructuring. Key support comes from international tax specialist Jorge Dávila, who specializes in international tax matters and was appointed partner in 2015; customs expert Carolina Rodríguez, and Natali Huaylla who focuses on tax litigation. An impressive client list includes Blackrock, Michelin, Starbucks, Cisco Systems, American Express, General Electric, Clorox, Jet Blue, Panasonic and Goldman Sachs. As we go to press, Lazo’s departure for Rodrigo, Elias & Medrano Abogados has been announced; the impact of his departure remains to be assessed.

Osterling Abogados delivers ‘good advice regarding tax law, promptly replies to its clients’ requests, and offers good value for money.’ The practice has a strong specialisation in all aspects of the mining sector and is also noted for its strength in tax litigaiton. Practice head Cristina Chang ‘gives precise responses and has the ability to simplify complex issues’, and has extensive experience of tax M&A structuring, corporate reorganizations, financial and capital markets, tax planning and tax litigation; specialised in mining tax law, she is also a member of the tax commission of the National Mining, Oil and Energy Association (SNMPE). Her colleague José del Castillo has the ‘ability to draw concise conclusions from a large body of data’; he specializes in tax litigation, corporate reorganisations international tax and compliance matters, with a particular focus on mining and construction tax issues. The ‘enthusiastic, dynamic and always available’ Raúl Aguinaga focuses on tax litigation, corporate reorganisations, international tax and compliance matters, and has particular expertise in the pharmaceutical and mining industries. Recent matters include advising a number of mining companies in administrative litigation regarding contributions levied by the Environmental Administration (OEFA) and OSINERGMIN; and Nyrstar on the tax implications and planning of the transfer of 100% of the shares of mining subsidiary Myrstar Coricancha. Clients include the Peruvian subsidiaries of Merck and Sanofi-Aventis, along with Inversiones Breca, Grupo Volcán, Rimac Seguros, Seguros Sura, and Profuturo.

The tax practice at Rebaza, Alcázar & De Las Casas Abogados Financieros primarily handles transactional matters in support of the firm’s highly regarded M&A and financial practices, particularly tax planning, structuring and optimization. The team also handles litigation, albeit to a lesser extent than transactional work. Partner Camilo Maruy is supported by a number of senior associates, including Melisa Bush, Gustavo Tarazona, Andres Gjurinovic and Carla Carranza.

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