Area of ​​Specialization

Transfer Pricing

  • Development of comprehensive studies.
  • Development of a functional, economic and financial analysis
  • Search for comparable companies and agreements.
  • Outsourcing services for firms.
  • Drafting of affidavits regarding international transactions.
  • Preparation of supporting documentation.
  • Previous studies for companies starting operations with related companies.
  • Studies for other countries in the Ibero-American region (Ecuador, Spain, Mexico, Peru, Uruguay) pursuant to each country’s domestic legislation.
  • Counselling and technical assistance.
  • Defence and remedies at an administrative level and before the National Tax Court against claims made and adjustments imposed by tax entities in relation to transfer prices.

International Taxation

Counselling and international tax planning
  • Strategies for tax optimization of:
    Commercial and international financial operations.
    Individuals’ considerable assets.
    Setting-up affiliates and branches abroad.
    Creation of affiliates or branches in the national territory.
    Tax credits collected abroad.
  • Tax counselling on:
    International consolidations and mergers, and acquisitions.
    Purchase or sale of share blocks..
    Purchase or sale of share blocks.
    Real estate investments in the country.
  • Tax residence
  • Withholding from payments made abroad (technology agreements, copyrights, royalties, interest, etc.)
Corporate structures
  • Analysis and tax optimization of existing corporations.
  • Management of corporations abroad (through associated accounting firms)
  • Counselling on the creation of “holding” companies, companies owning intangible assets and trading companies.
  • Asesoramiento para la constitución de sociedades holding, propietarias de intangibles y comercializadoras (trading).
Succession and tax planning for family business
  • Trust.
  • Non-Profit Associations.
Artistes and Sportsmen
  • Tax counselling on:
    Wages and other sorts of compensations.
    Image rights.
    Representation agreements.
    Advertising agreements.
    Commercial sponsorship.
Expatriate Executives
  • Tax analysis of:
    Work and assets revenues.
    Other revenues.
  • Transfer impact on tax and finance.
    Compensations and reimbursements.
    Cost equalization.
    Tax protection.
  • Tax aspects of residence change and double taxation
  • Pension plans and stock options.
Agreements to avoid Double Taxation
  • Agreement analysis and applicability.
  • Counselling on specific probable cases of international double taxation.
  • Counselling on Treaty shopping.