Argentina

Baker Mackenzie’s tax practice is known for its presence providing tax advice worldwide.  In Argentina, the team is led by Martín Barreiro and supported by fellow partners, Juan Pablo Menna, and Esteban Rópolo.   

During the research period, the team advised Facebook regarding new regulations applicable to the gross receipts tax, VAT, and income tax collections on the provision of cross border digital services.   Additionally, the firm provided advice on tax planning alternatives to implement reorganization for the Schlumberger Group.

The firm welcomed Felix Secchi and Lucia Pagella as associates.

Client feedback

“Creativity, nuanced consideration of risks and benefits of alternative approaches, responsiveness.”

“Responsiveness and technical skills.”

“extremely detail oriented and attentive to latest precedents.”

“Efficiency. Quick response. Intelligence of market.”

“Swift straight forward responses. Insightful inputs.”

“The Tax team is absolutely reliable, professional and willing to exchange ideas. They are efficient, effective, punctual and clear in their presentations and comments. Its solidity is indisputable.” 

The tax department at Bomchil advises in various tax areas, such as general corporate tax, tax controversy, indirect, and transactional tax. The firm also advises individuals, particularly on estate taxes, family office and inheritance planning. The team consists of four partners and six associates. Clients belong to various sectors including agribusiness and agricultural products, oil and energy, generation, transportation and distribution of electricity, financial and insurance services, food and dairy products, media, tourism, professional services, software, and digital economy businesses, among others.

During the research period, the team advised Argentine oil and gas company Compañía General de Combustibles (CGC), one of Argentina’s largest debt issuers in 2022, on its various financial and capital market transactions.

Client feedback

“Practical and business oriented  advice.”

“Great knowledge of the industry and the law.”

“Sharp knowledge with accurate tax advice; hands-on; high quality services.”

The tax department at Bruchou Fernández Madero & Lombardi, which includes transfer pricing, is made up of four partners and 15 lawyers, headed by Matías Olivero Vila. The team is active in diverse sectors such as agribusiness and food packaging. As a Tax and network member, the firm has a strong presence in the international market.

During the research period, the firm filed a lawsuit on behalf of two local bank associations, Asociación de Bancos de la Argentina and Asociación de Bancos Argentinos and several banks to challenge the constitutionality of specific legislation levying specific bank operations with turnover tax.  The firm also filed a lawsuit to challenge the constitutionality of a withholding tax regime regarding the turnover tax of the province of Buenos Aires.  Finally, the team filed a lawsuit before the courts of the City of Buenos Aires to challenge an information regime approved by the tax authorities of the city. Regarding the lawsuit against the city of Buenos Aires, the team can highlight that it is the first one in which this matter is being discussed in courts and the possible outcome will be important to other provinces of Argentina.

Client feedback

“Smart. Efficient. Serious”

“The service has always been excellent in every way. Bruchou has extensive experience in M&A and international transactions. The response time, an essential requirement to hire a Law Firm in these times, is perfect, they are fully aware of modern business times. They have always shown us their enormous management and experience in M&A negotiations, which has generated significant benefits for us in the transaction. In tax matters, Ezequiel Lipovetzky, who has shown great responsiveness (he is always available in a timely manner to resolve issues) and experience in tax advice on M&A and international tax planning. He is an excellent lawyer who has also shown us to be very practical in coordinating a transaction from a tax point of view, since he does not stay strictly technical (like many tax advisors) but rather takes it to the practical aspects applicable to the transaction. This quality sets him apart from other lawyers. We have noticed that the tax team is extensive and some of them have participated in the transaction, such as Pablo Muir. The excellent coordination of the team by Ezequiel Lipovetzky is a quality that is also of great value to us.”

“with advise, legal opinions and structuring.”

“They are very proactive, client oriented and always looking for a solution.”

“hey have a very professional and highly qualified work team. They are very flexible and creative when it comes to finding solutions. You can always count on them and their resolution times are very fast”

“precise advice and explanations of different possibilities and variants.” 

The Big Four accounting firm is among the leading firms for transfer pricing services offering a comprehensive TP service. The TP team has experience assisting large multinational companies across various industries such as manufacturing, energy and resources, agribusiness, financial services and more. Hernán Diez and Silvana Blanco are among the TP experts leading the practice. Deloitte Argentina tax and legal team, led by Atilio Cataldo, has 250 professionals. 

During the research period, Deloitte assisted its client in carrying out a Mutual Agreement Procedure to eliminate double taxation in accordance with the provisions of the Double Taxation Treaty.  The present case could be one of the first Mutual Procedure Agreements on transfer pricing that will be discussed by the Argentinean Competent Authority and thus have repercussions on future cases.

Client feedback

“DT Argentina, is always available for any questions, very proactive.”

Grupo GNP is an organization founded in 2006, consisting of approximately 30 people, under the leadership of Guillermo N. Perez. The company service lines include, but are not limited to, tax strategy, fiscal audits, tax legal services, local and international consulting, business process outsourcing (BPO), and transfer pricing. The firm specializes in advising corporations, however, can service family businesses. 

Among many clients and matters serviced this research period, Grupo GNP worked to advise a client in updating its accumulated tax loss due to inflation.  The importance of the work done is linked to the possibility of uniformly applying the tax inflation adjustment to all matters related to income tax, by preventing the inflation that exists in Argentina from devaluing the tax losses.

Tax seniors Alejandro Peralta and Jimena Pazos both departed to local companies.  Additionally transfer pricing senior Emanuel Gómez departed to one of the Big Four.  However, the firm welcomed two tax managers, Ezequiel Barbalaco and Leandro Ameri, and two tax seniors Juliana Pattaro Ezequiel Cano all from local firms.

Laiún, Fernández Sabella & Smudt advises on general corporate tax and is specialized on transfer pricing matters.

During the research period, the firm worked on a transfer pricing policy for several lithium mining companies in Argentina.  The work done has important implications for the mining industry which has one the greatest impacts on the country’s macroeconomy both in terms of tax collection, employment generation, and foreign exchange earnings from exports.  

During the past year, tax senior Erica Benotti departed to Megatone along with transfer pricing senior, Patricia Bruno leaving for IMS Internet Media Services. However, the firm promoted tax seniors Agostina Manganese, Antonella Villa, Nahuel Chiprut Abad. Additionally, Guadalupe Martinez Manzolido and Lucia Szpayzer were promoted to transfer pricing seniors.

Client feedback

“All members of the team are excellent professionals, giving a complete scope of the pros and cons of how we have to drive our activities.” 

“Perfect memos and responses times are unbeatable.”

“Efficient approach, facilitating compliance for our Company.”

“Very knowledgeable. Analyse and identify various solutions to problems highlighting pros and cons of each.”

“They are extremely knowledgeable of the tax subject matter, but more importantly, very good problem solvers, and can understand our situation and needs quickly, and can be very flexible and dedicated to provide timely and to-the-point advise of excellent quality when requested.” 

The tax team at Marval O’Farrell & Mairal consists of 31 professionals led by five partners: Gabriel Gotlib, Horacio García Prieto, Walter Keiniger, María Inés Brandt and Fernando Vaquero. The Argentine powerhouse’s strengths lie in general corporate tax, tax controversy, indirect tax, and transactional tax, with an emphasis on cross-border transactions and M&A. The firm is active in the agribusiness, private equity, energy, and natural resources sectors. 

During the research period, the firm advised Mondelēz Argentina in the negotiation and execution of an asset sale agreement which included the Mantecol brand, the factory located in the City of Victoria, and other assets. Assistance also included the implementation of various commercial agreements between the parties.  The complexity of the deal resided in the variety of assets involved, including trademarks and a factory, as well as different contracts.

Client feedback

“Marval's Tax professionals are highly recommended in the practice areas.”

“Biggest and number of deals.”

“They are very competent in dealling with tax matters.”

Manuel Benites, the founding partner, leads the tax team at Pérez Alati Grondona Benites & Arntsen, along with partner Marcelo Nuñez. The team specializes in tax controversy, transfer pricing, and transactional tax, specifically M&A and cross-border transactions. It works with clients in many sectors such as agricultural exports, automobiles, forestry and paper, oil and gas, pharmaceuticals, and retail.

During the research period, the firm represented Pan American Energy Group concerning the tax on liquid fuel and natural gas. The decision is not yet final; however, the results have major implications given the role fuel and gas play in Argentina’s economy. The precedent could impose a limit to tax claims which would otherwise illegally increase the heavy tax burden faced by the industry.  

Client feedback

“They know our industry and our company.”

“they are very good in the two fields mentioned above. Very good team headed by Manuel Benites.”

Rosso Alba & Rouges is a leading boutique firm founded in 2004 that specializes in international tax, tax controversy, and transfer pricing. Along with its partners, associates, and counsel, the firm also employs two in-house transfer pricing economists and two accountants. The tax team advises clients in the agricultural export, industrial manufacturing, food and beverage, construction and utilities, oil and gas and service and retail sectors. 

During the research period, the team was hired by Bunge to challenge Presidential Decree No. 131/2022 on constitutional grounds, given that it raised the export duties corresponding to agro-industrial products without Congressional approval. The company obtained a judicial injunction preventing the Argentine Revenue Service from collecting the incremented export duties during the judicial controversy. 

Semi-senior Maria Belen Grane left for EY in March of 2023.  However, the team welcomed new semi-seniors Rodrigo Diaz from of Litvak & Asociados, Bautista Penna from the tax department of Universidad Torcuato Di Tella, and Tomas Schiavini Weiner, Soto & Caparròs. In addition, the firm recruited two new seniors: Fausto Geremia who was formerly the head of Taxes from Pomelo Tech and Marcos Quiroga Pizzorno, a former associate at studio Angulo-Mendizabal.

TPC group is a firm specialized in Transfer Pricing Consulting. They advise multinational companies, providing tax planning service and reviewing Transfer Pricing Reports.  

The case work and clients are to remain confidential.

The firm witnessed the departure of various team members to study including Renato Seminario, Jose Daniel Martinez, and Marco Mozombite. Magaly Casasola left for personal reasons. However, TPC Group welcomed two new transfer pricing analysts, Antuane Zanabria Calle and Fiama Guerra Jimenez.