• Experience

Experiencias

We have experience in providing advisory services for the most relevant industries in the country. We keep a close relationship with our clients based on trust and a professional and honest treatment. Our network of more than 100 correspondents worldwide, along with the international experience of our professionals, have allowed us to advise relevant business groups on the internationalization of their operations, as well as to support foreign clients for their businesses in Peru.

We advise national and international mass consumption companies. We have analyzed prospectively and with results proven to be accurate the tax impact of their most relevant operations and we have defended their interests in tax matters before administrative and judicial authorities with a significant level of success.

We advise the main airlines in the region. We know firsthand the challenges that the aviation sector faces in tax matters. We have helped our clients in obtaining uniform criteria from the Tax Administration regarding typical operations of the sector, and we have achieved the setting of precedents for the correct interpretation of norms contained in international agreements to prevent double taxation.

We have given support in the recognition of the nature and added value of the operations carried out by companies based abroad, as well as in certifying the acquisition of Financial Derivatives as a protection tool.

We have experience in advising agribusiness export companies on the correct planning of their operations to take adequate advantage of the benefit regimes established in our legislation. We have advised and identified solutions for recurring complex situations in the sector, such as accumulated credits, use of tax losses, capital structuring, internationalization of operations, etc.

We have represented an important taxpayer from the gas and oil sector in a tax administration objection, achieving the correction of significant objections in the first administrative instance before SUNAT.

We advised a leading Peruvian company listed on a foreign stock exchange on the structuring of the selling of a significant block of shares.

We advised a leading Peruvian company on the reorganization of its share and group structure, implementing corporate tools that allowed it to expand its operations abroad in a more efficient way.

We advised one of the most important Peruvian Multi-Latin companies on building its succession plan for the next family generation.

We successfully handled before the Tax Administration certificates for recovery of invested capital, to enable the deduction of the cost basis of the investments in the country made by non-domiciled taxpayers.

Our experience in tax litigations includes successful decisions by the Tax Court and other Courts on Income Tax, General Sales Tax and Transfer Pricing matters. We have achieved precedents of mandatory compliance and favorable rulings in the first instance (SUNAT) on matters of substance related to international operations.

We have achieved satisfactory results in the defense of our clients regarding conflicts with the SUNAT on matters such as: (i) due interpretation and enforcement of Double Taxation Agreements signed by Peru, (ii) due interpretation and enforcement of transfer pricing regulations, including the associated OECD Guidelines, (iii) recognition of the nature and purpose of different financial derivatives as coverage strategy, among others.

We have supported our clients during their tax audit procedures, to solve at this stage, the fiscal objections, thus preventing administrative and judicial disputes, and we have provided in a timely manner the means of proof required by the Administration, which may be used in case of an eventual dispute, without the obligation to pay or pledge the debt under discussion. At the audit stage, we have managed to solve significant objections, saving the client unnecessary costs.

We represented clients from the construction sector and others regarding tax assessments and refunds of incorrectly charged taxes in judicial proceedings, obtaining favorable resolutions that involved significant amounts for the companies.

After representing a client for more than 20 years before the administrative and judicial courts, we obtained a favorable ruling by the Supreme Court of Justice that recognized its right to a refund of a significant sum of money for incorrectly paid tax.

We advised our clients in carrying out due diligence reviewsestablish their legal situationor that of target companies that they were interested in acquiring, in the corporate, administrative, regulatory, contractual, tangible property and labor fields.targetSaid reviews have been carried out to identify eventual contingencies that could have a negative impact on a potential future buying or selling of the shares representing the capital stock of our clients and/or the referred target companies.

We advised an large company of the metallurgical sector on the negotiation and selling of the shares representing its capital stock to another important company of the same sector. Our work consisted in negotiating with the other party’s lawyers all the terms and conditions of said contract (with special clauses on the selling price, its determination and form of payment, representations and warranties, responsibilities of the parties, tag along and drag along rights, non-competition, among others), until the signing of the contract and all the additional documents for closing the operation.

We advised an important pharma company on the design and implementation of a corporate reorganization procedure (spin-off) thus different assets and liabilities were segregated and transferred to another company of the same business group, to generate economic and administrative efficiencies in the operations of both companies. Our work consisted in preparing all the documents required for said corporate reorganization (spin-off draft agreement, minutes of annual shareholders’ meetings and board of directors’ meetings, sworn statements and articles of incorporation) as well as their notarization and subsequent registration.

We advised an important transport company on the design and implementation of a corporate reorganization procedure, to reduce the number of companies of the business group, thus obtaining a better administrative and operative efficiency within the business group itself. This procedure involved the change of address to Peru of a company incorporated abroad (passing, to this effect, through more than one jurisdiction), its subsequent absorption (merger) of the redomiciled company by another company of the same group, and the implementation of important additional acts related to the designed structure (preparation of the shareholder agreement, partial amendment of the corporate bylaws, among others).