Tax structuring is central to the value our lawyers deliver in M&A, private equity, capital markets, and financing transactions. We advise buyers and sellers on the tax dimensions of acquisition structuring, including the choice of transaction vehicle, the contractual allocation of tax risks in agreements, the identification and quantification of tax contingencies through due diligence, reviewing the tax component of buy-side and sell-side financial models, and the design of post-closing integration structures that minimize tax friction. For private equity sponsors, we advise on fund formation, portfolio company structuring, leveraged acquisitions, and exit transactions, addressing both Mexican tax and the international tax considerations that arise when sponsor capital flows through multiple jurisdictions.

In capital markets, we advise on the tax aspects of debt and equity issuances in both the domestic and international markets, including the structuring of certificados bursátiles, cross-border bond offerings, structured finance vehicles, and the FIBRA and FIBRA-E regimes that govern listed real estate and infrastructure investments in Mexico. For lenders and borrowers in financing transactions, we advise on the withholding tax implications of cross-border loan structures, interest deductibility, and the application of Mexico’s thin capitalization, earnings stripping, and anti-hybrid rules to complex financing arrangements.

Beyond transaction support, the Firm provides ongoing tax advisory services to corporate clients operating in Mexico and Mexican corporates on their outbound investments, advising on tax treaty application, corporate income tax, VAT, transfer pricing, and other federal and local taxes; structuring intercompany arrangements and cost-sharing agreements within applicable legal frameworks; and monitoring legislative and regulatory developments that affect clients’ tax positions. The Firm maintains a dedicated transfer pricing practice staffed by experienced professionals who advise on strategic high value matters that arise as a result of our ongoing tax advisory work.

Our corporate tax advisory work is distinguished by the integration of technical depth with commercial practicality. Mexico’s tax framework is complex, and its application to specific commercial arrangements frequently requires creative analysis that goes beyond the literal application of statutory rules. Our lawyers are recognized for the quality of that analysis, the ability to identify and defend positions that serve our clients’ interests, and to communicate those positions clearly to business decision-makers, audit committees, and tax authorities alike.

The Firm’s tax controversy practice is focused on assisting in complex, cross-border, financial and tax treaty-related matters. The team takes a proactive approach, collaborating closely with clients to understand their unique situations, as well as with authorities and courts to craft innovative strategies that safeguard clients’ interests while striving for favorable outcomes.  We focus on resolving tax controversies at the earliest administrative stage possible, achieving significant success in this approach.

Our tax controversy practice has extensive experience in managing tax audits, filing tax refunds, representing clients before PRODECON (Taxpayers’ Advocate Office), handling administrative appeals, MAPs, litigating in tax courts, and executing amparo procedures.  The Firm prides itself on its technical prowess in tax substantive matters, allowing it to craft innovative and effective solutions for any controversy that may arise.  The practice maintains a keen eye on potential future litigation needs, pre-empting any issues that could surface in court proceedings.

The synergy of our tax controversy practice with our transfer pricing practice provides clients a one-stop-shop to resolve their tax controversy matters comprehensively.

Mexico’s active participation in the OECD’s Base Erosion and Profit Shifting project and, its network of double taxation treaties, have fundamentally altered the international tax environment for companies operating in or through Mexico. We advise multinational corporations, financial institutions, and private equity funds on the Mexican dimensions of their international tax structures, including treaty eligibility concerns, withholding tax, permanent establishment risk, anti-avoidance rules, and the application of Mexico’s controlled foreign corporation regime.

Our international tax practice is connected to the Firm’s cross-border M&A and project finance capabilities. The same transactions that require Mexican law expertise on their corporate and financing dimensions also require a sophisticated understanding of how those structures interact with the tax systems of the US, UK, European, and Latin American jurisdictions that are most commonly present in cross-border mandates involving Mexico. We coordinate with international co-counsel on these dimensions as a matter of course, ensuring that the Mexican tax advice we provide is calibrated to the broader international tax architecture of each engagement.

Transfer pricing has become one of the most active areas of tax enforcement in Mexico, with the SAT devoting increasing resources to the review of intercompany pricing arrangements across all major industries. Our transfer pricing team provides end-to-end advice: from the design and documentation of arm’s-length pricing policies, through the negotiation of advance pricing agreements (APAs) with Mexican and foreign tax authorities under the mutual agreement procedure, to the defense of transfer pricing positions in audit and dispute contexts.

We advise clients operating in manufacturing, services, financial transactions, intellectual property licensing, and commodity trading, the sectors where transfer pricing risk is most concentrated and where the consequences of inadequate documentation or aggressive pricing positions are most severe.

The Firm advises clients on the policy dimensions of Mexico’s tax framework, engaging with regulatory reform processes on behalf of industry groups and individual clients, advising on the tax implications of proposed legislation before its enactment, and providing analysis of regulatory guidance as it develops. This policy advisory capability reflects the depth of our engagement with Mexico’s tax system, and the relationships our lawyers have built through years of practice at the intersection of tax law and public policy.