Tax: Non-contentious and Controversy
Nuestro equipo fiscal asesora a empresas e inversionistas a lo largo de todo el ciclo de sus asuntos tributarios, desde la planificación y estructuración de operaciones hasta la atención de auditorías, revisiones y litigios complejos. Ofrecemos un servicio integral que combina consultoría y controversia fiscal, con un enfoque estratégico orientado a gestionar riesgos, asegurar el cumplimiento y respaldar las decisiones de negocio de nuestros clientes.
We advise on the tax planning and structuring of domestic and cross-border operations, including corporate reorganizations, financings, investments and long-term projects. Our work focuses on assessing tax implications, identifying risks and designing efficient structures aligned with our clients’ business strategy.
We support clients in meeting their recurring tax obligations and in the correct application of applicable regulations. Our team reviews relevant tax positions, assists in the preparation and documentation of key requirements, and helps design internal processes that promote certainty and reduce exposure to potential contingencies.
We participate in mergers and acquisitions, joint ventures, divestments and financing transactions, evaluating the tax impact of each proposed structure. We work closely with corporate, financial and regulatory teams to ensure that every transaction is implemented with sound, well-documented and sustainable tax design.
We advise on the application of double-taxation treaties, permanent establishment rules and withholding obligations in cross-border operations. Our work includes analyzing investment structures, capital flows and intercompany payments, offering solutions that comply with applicable standards and provide long-term certainty.
We represent taxpayers in audits, desk reviews and on-site inspections initiated by the tax authorities. We assist at every stage—from responding to information requests to addressing preliminary findings—ensuring positions are well supported and risks are properly managed.
We design and implement defense strategies in administrative proceedings, including refund requests, administrative remedies and other mechanisms for dialogue with the authorities. Our approach combines solid legal arguments with practical alternatives to mitigate risk and protect cash flow.
We litigate tax disputes before administrative and judicial courts, challenging assessments, penalties and other actions that impact our clients’ operations. Our team focuses on building technically robust cases supported by legal criteria and aligned with the taxpayer’s business objectives.
We assist in negotiating and resolving complex controversies with tax authorities, assessing risk scenarios, economic exposure and available regularization alternatives. We participate in strategic discussions and settlement processes to achieve solutions that provide certainty and allow clients to focus on their core business activities.
Prizes
Advised SDC Capital Partners on the development of high-capacity data centers in Mexico. Our counsel included environmental impact analysis, federal permitting, compliance before SEMARNAT, and coordination with state and municipal authorities.
Advised Copenhagen Infrastructure Partners (GIP) on the development of a 759 MW wind farm in Mexico, including environmental impact assessment, key permits, and compliance strategy aligned with international standards.
Represented a global hotel chain in environmental litigation following a closure order by authorities in a protected coastal zone. We successfully overturned the measure and redesigned the company’s environmental compliance strategy.
Advised a specialized infrastructure fund on the environmental evaluation of a next-generation urban mobility system, including permitting, site analysis, community engagement, and alignment with environmental regulations.
Conducted a comprehensive environmental audit for a nationally operating manufacturing company, including hazardous waste regularization, NOM compliance, and support during PROFEPA inspections.
Provided legal counsel and support to a climate-tech start-up securing sustainability-focused financing in the agricultural sector.
Advised on potential sites and pre-feasibility studies to determine land use restrictions and territorial planning for the development of wind and solar farms.
We advised Bayer on a comprehensive evaluation of its corporate criminal liability, with a focus on anti-corruption risks and the design of a robust Criminal Compliance Program. The project includes the development of internal criminal policies, controls to mitigate risks previously identified by its compliance team, and alignment with local and international regulations, such as Article 421 of the National Code of Criminal Procedure and the Law on Biosafety of Genetically Modified Organisms. Given the complexity of its operations and the sensitivity of the biotech sector, the model implemented positions Bayer as a benchmark in criminal liability and corporate governance in Mexico.
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We led a comprehensive review of Arauco México’s Crime Prevention Model, with a focus on environmental and criminal risks. We conducted an organizational diagnosis, proposed adjustments to their compliance policy, and delivered training sessions for their executive team. The project enhanced the company’s ability to anticipate and mitigate legal risks related to environmental criminal liability.
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We advised IEnova on the design and implementation of an environmental criminal compliance system, in accordance with Mexican and international law. The model included risk assessments, crime prevention manuals, and awareness sessions for executives, focused on mitigating risks arising from third-party conduct. The solution aligns with UNE 19601, the Federal Environmental Liability Law, and U.S. DOJ standards.
We designed and implemented a corporate criminal compliance management system for Citibanamex, aimed at mitigating legal risks through a structure adaptable to various areas of the bank. The model included operational controls, reporting protocols, incident response mechanisms, and a comprehensive internal training program. The solution was developed jointly with legal and corporate security teams and can be deployed both institutionally and by business division.
Designed and implemented a compliance program focused on anti-corruption and business ethics, including specialized training on Mexico’s National Anti-Corruption System and the FCPA for the board of directors, as well as on-site sessions in Hermosillo for suppliers, strengthening a culture of compliance across the value chain.
Prepared legal memoranda for Skadden on compliance requirements under Mexican law, including analysis of registration and reporting obligations in interactions with employees and representatives of state-owned entities for transactions such as joint ventures and natural gas offtake agreements, as well as a memorandum on restrictions regarding gifts, meals, and hospitality, with practical recommendations to mitigate enforcement risk before Mexican authorities.
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We advised Riverstone on the creation of VEMO through the merger of four clean mobility companies.
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We advised Televisa on the sale of its 40% equity interest in Ocesa to Live Nation.
We represented Planigrupo’s Special Committee in connection with unsolicited acquisition offers, which led to an agreement with Grupo México.
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We advised Javer and its main shareholders on the tender offer launched by Vinte to acquire up to 100% of the company.
We advised Televisa on the combination of its media and content assets with Univision.
We advised Prosus on its approximately USD 1.7 billion acquisition of Despegar.com.
We advised Alfa on the spin-off that resulted in the creation of Controladora Alpek as part of its corporate restructuring.
We obtained the Declaration of Fame for the “Chantilly” brand before the Mexican Institute of Industrial Property (IMPI), through a process that involved accreditation of experience, recognition, commercial presence and continuous use in the market.
We advised Grupo Presidente on the conciliation processes with EGEDA, a collective management company for audiovisual rights, for the use of protected works on televisions installed in its hotel chain. The issue raises a key discussion about the scope of copyright in public spaces where content is not the main service.
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We represented Valia Energía in its first international bond issue since 2020, backed by energy assets in operation.
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We assisted CIP in the legal structuring of a pioneering green hydrogen project in the Isthmus of Tehuantepec, including permits, agrarian agreements, environmental licenses and relationships with key agencies such as CFE and PEMEX.
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We advise Mexico Pacific Limited on all regulatory and contractual aspects related to the development of a large scale natural gas liquefaction terminal.
The team comprises a highly skilled group of professionals, including public accountants, who provide independent tax advice and regularly support other practice areas of the Firm, particularly in the context of complex cross-border mergers and acquisitions transactions.
In addition, our Firm is distinguished by the wide range of matters of any nature and complexity in which we have participated, as well as by the professionalism of our multidisciplinary team and its ability to provide different solution alternatives in complex tax disputes and litigation to our clients.
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