Client Alert | June 12, 2023
Peru: Binding precedent of mandatory compliance with respect to tax residency certificates established
Tax
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Chambers & Partners
Practices 2021 2022 2023 Tax Band 3 Band 3 Band 3 Testimonials
Band 3: Chambers and Partners — 2023
Estudio Echecopar - Baker McKenzie is an accomplished full-service firm with an international presence and a taxation department providing assistance to clients on matters such as the tax structuring of M&A transactions, wealth management and regulatory analysis. The team demonstrates the ability to attract clients from the real estate, food and beverage, oil and gas, and financial services industries. Ajeper, Unilabs and Gloria count as new client wins.
Strengths "Estudio Echecopar - Baker McKenzie's tax team always try to place themselves in our shoes and offer us tailor-made solutions based on their specialised knowledge of our business. They also provide fiscal advice that has a low impact on our business."Work highlights Estudio Echecopar - Baker McKenzie advised IBM Group on the tax implications of the corporate reorganisation of its subsidiaries in Peru.Band 3: Chambers and Partners — 2020
"They provide us with very good legal services and solid answers to our questions, in addition to making good recommendations and developing sound strategies. They are strategic."
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The Legal 500
Practices 2021 2022 2023 Tax Band 2 Band 2 Band 2 Testimonials
Band 2: The Legal 500 — 2023
Estudio Echecopar member firm of Baker McKenzie International fields a team of ‘very outstanding professionals and resolves queries immediately and efficiently’. Leaning on its vast global network for support, the practice handles international tax matters with ease and is particularly experienced in tax-related corporate transactions, including M&A, and also reorganisations. It acts for a strong roster of multinational clients as well as smaller Peruvian companies, and in addition to its non-contentious corporate expertise, handles tax litigation proceedings before the Peruvian Tax Authorities. Rolando Ramirez-Gaston Horny heads the practice; with over 20 years’ experience in the field, he is well versed in wealth planning, tax audits and transactional issues. At associate level , principal associates Carla Peirano Castañeda, Cristina De La Piedra and Dora Ramos are recommended.
‘We have been using the services of the firm for years and it seems to us that their level of commitment and attention to the client is very high compared to other firms‘.
‘All the lawyers are very outstanding professionals and resolves our queries immediately and efficiently‘.
‘Very good tax team, reasonable deadlines for acquittal of queries, always available, and high level of knowledge on the matter‘.
Band 2: The Legal 500 — 2019
"Frontline professionals who are highly trained".
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International Tax Review
Practices 2018 2019 2020 Tax Band 1 NR NR Testimonials
International Tax Review 2018
Tier 1: Transactional Tax
Tier 2: Indirect Tax y World TaxInternational Tax Review 2015
Latin American Firm of the Year in Tax Practice - 2015
Description
Clients face the changing world of taxes every day, which mainly nourishes from changes and trends coming from the international scenario, such as the BEPs initiatives of OECD countries and international treaties on tax matters.
In order to face up to this reality, Estudio Echecopar, in association with Baker & McKenzie International, is the Firm that can better respond to client needs to navigate this world.
Our tax area is oriented towards answering queries on tax effects of different transactions, investments and deals that our clients make in Peru, both national and foreign companies, providing solutions to every challenge our clients may encounter when conducting their business.
An outstanding feature of our practice is our specialization in advising on the supervision proceedings, and in conducting defense in tax claim proceedings before the National Superintendence of Tax Administration (SUNAT, in Spanish), the Tax Court, municipal governments and the Judiciary.
We have considerable experience on tax planning to look for efficiencies in the management of our clients' income and expenses from a fiscal point of view. We stand out for doing intensive planning and structuring work in mergers and acquisitions, as well as sophisticated financial operations, including syndicated loans, bond issuance (in Peru and overseas), international public offerings, assets securitization, investments through mutual funds and investment funds, including Real Estate Investment Funds (FIRBIs, in Spanish) and Real Estate Investment Trust (FIBRAs, in Spanish) with the lowest tax cost possible..
Our Tax area advises on tax analysis of the payments made to non-domiciled companies (technical assistance, royalties, digital services, interests, and dividends, among others), and on determining the possibility of establishing permanent headquarters for foreign companies that provide such services.
We offer planning and advice on treaties to avoid double taxation entered into by Peru, which allows us to advise on creating and, if applicable, optimizing corporate structures of our clients at regional and/or international level. We have advised various corporate groups in the reorganization of their corporate structure, both locally and internationally, actively working together with our offices located in the principal cities of the world.