Experience
Selected matters in tax litigation, controversy, refund recovery, and transactional work.
USD $441M
Corporate restructuringDesigned and implemented a corporate restructuring involving the Mexican investments of a foreign pension and retirement fund. The reorganization was structured to safeguard the fund’s investments in Mexico, which were subject to a preferential Income Tax regime. The transaction value exceeded USD 441 million.
USD $25M
VAT · Pre-operating periodsRepresented the tax interests of a foreign corporation and its Mexican subsidiaries in connection with the construction, development, and commencement of operations of two renewable energy projects in Mexico. Implemented a strategic legal framework that enabled the recovery of USD 25 million in VAT favorable balances generated during pre-operational periods.
USD $150M
CERPI · BMVActed as tax counsel in the issuance of Investment Project Trust Certificates (Certificados Bursátiles Fiduciarios de Proyectos de Inversión – CERPI) listed on the Mexican Stock Exchange, for an aggregate amount of up to USD 150 million.
USD $293M
Cross-border M&AActively advised on the acquisition of shares of a Mexican subsidiary operating in the ceramic manufacturing industry. The transaction, valued at approximately USD 293 million, involved complex tax considerations that were critical to the negotiation and structuring of the share purchase transaction.
USD $160M
Conclusive agreementAdvised a financial services aggregator in Mexico in the negotiation of a conclusive agreement (acuerdo conclusivo) with the Mexican tax authorities, achieving a reduction of approximately USD 160 million in potential tax exposure.
USD $500M
Transfer pricingParticipation in a high-complexity conclusive agreement (2022) addressing a tax contingency exceeding USD 500 million for tax years 2013–2016. The matter involved transfer pricing, presumptive determination of silver pricing, tax treaties, and transactions with foreign residents, and had significant subsequent regulatory impact.
USD $150M
Supreme CourtLed, with the team, strategic tax litigation involving USD 150 million, obtaining the annulment of the assessment before Mexico's Supreme Court of Justice. One of the most significant tax litigations in recent years by quantum, procedural complexity, and constitutional relevance.
Amparo
Fuel excise taxObtained a favorable amparo ruling declaring unconstitutional the 2019 Miscellaneous Tax Resolution rule that barred mining companies with revenues above MXN 50 million from applying the fuel excise tax credit against income tax. A strategically significant matter for its constitutional and sectoral impact.
98%
USD $50M → USD $1MCoordination and negotiation of a conclusive agreement following a tax audit, through which a contingency of approximately USD 50 million was reduced to USD 1 million. Reflects an effective strategy of defense, negotiation, and resolution of disputes with the tax authority.
Income Tax · VAT · Excise Tax
FY 2018Representation in a tax audit and conclusive agreement before PRODECON covering disputes on taxable income, deductions, materiality, intercompany transactions, financial instruments, exports, and indirect tax credits. A noteworthy matter for its technical breadth and the multiplicity of items in dispute within a single review.
MXN $125M
VATImplementation of a defense strategy via administrative appeal (recurso de revocación) to recover approximately MXN $125 million in VAT credits whose refund had been denied by the tax authority. Representative of the firm's experience in refund matters, administrative remedies, and effective liquidity recovery for clients.
MXN $100M
13 appeals + 5 nullity proceedingsObtained rulings in 13 administrative appeals and 5 nullity proceedings to recover approximately MXN $100 million in VAT credits across different group companies. Demonstrates consistent execution in serial controversies of significant economic impact.
USD $340M
Cross-border M&ATax advisory on the structuring of the acquisition of a Mexican steel and metals distribution company by a leading European multinational, in a transaction valued at approximately USD 340 million, with significant components of tax planning and execution in a cross-border context.
Due Diligence
Hospitality · Riviera MayaHigh-level legal due diligence for the potential acquisition of a corporate structure owning hotel assets in the Riviera Maya. A particularly relevant matter showcasing experience in complex operations involving hospitality, real estate, and strategic transactions.
USD $50B
IMF Flexible Credit LineLegal implementation of Mexico’s US$50 billion IMF Flexible Credit Line, coordinating the legal structuring, negotiation, and execution of the necessary documentation to ensure full compliance with applicable regulatory and institutional requirements. This work contributed to reducing sovereign debt interest payments by US$4.9 billion through a precise and strategically designed legal framework that strengthened Mexico’s financial position and supported macroeconomic stability.
USD $22.7B
Banco de México liquidity facilitiesEstablished Banco de México’s legal framework for liquidity facilities during the Covid-19 pandemic, leading the drafting, review, and legal structuring of the provisions and contractual documentation required to implement such mechanisms. This included repos, credit agreements, securities lending arrangements, and trust structures, for an aggregate amount of US$22.7 billion. The work ensured full regulatory compliance, operational readiness, and timely execution of the measures designed to preserve market stability and support the functioning of the financial system during a period of extraordinary stress.
There are no matters in this area.
Some of the matters were led by members of the team during prior professional roles at other firms or institutions, where their role was central to the outcome.
