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Carla is experienced in tax consulting of national and foreign companies with special focus in the energy, oil & gas, mining and infrastructure industries.
Experience
Legal and tax advice to Anadarko Petroleum Corporation on a regular basis in connection with its recent entrance into the Peruvian upstream activity. We helped them to understand the hydrocarbons business climate and the local industry practices, the mechanics of the Peruvian model license contract, the applicable taxing, accounting and regulatory obligations.
Advised Peru’s leading university PUCP Peru in the acquisition of 25.1 hectares of public land from the Public Goods State Agency (Superintendencia de Bienes Estatales) for the building of a Science and Technology Park. Also, we advised PUCP regarding the technical assistance contract signed with Spanish Kunayala, company that has experience in the implementation and operation of technology parks around the world.
Advised Geologic Peru in a complex transfer pricing analysis that involved a US related party and a US Permanent establishment, and determining an appropriate TP policy that is valid for US and Peruvian purposes. In addition, it required the analysis from both a US and Peruvian tax perspective of the best legal structure that could be implemented to recognize the split of profits between Geo Logic Peru, its US permanent establishment and Geo Logic US.
Advised and represented HERBALIFE PERU in against a tax assessment made by the Tax Administration. In this case, SUNAT is rejecting the set of comparables used by HERBALIFE PERU in the Transfer Pricing Study for FY 2015 (TPS 2015). Our role included a thorough analysis of the transfer pricing rules, we proposed to analyse if the company had the same objection from the Tax Administrations in other jurisdictions where HERBALIFE is present and preferably, if such jurisdictions are OECD jurisdictions.
Advised and represented Dupree in a tax audit carried out by the Tax Administration. In this case, SUNAT purported to reject some of the comparables used by DUPREE in the Transfer Pricing Study for FY 2015 (TPS 2015). Our role was aimed at demonstrating that the Tax Administration has made a cherry-picking when selecting the companies that shall be excluded from the comp set.
Assisted Amazon Web Services Inc. in several tax issues. Our team was appointed to understand Amazon Web services (mainly cloud computing services) and its offerings in Peru to assess all direct and indirect taxation implications, including, primarily, an exhaustive Permanent Establishment analysis under the recently amended Peruvian Income Tax Law.
Advised CAF in connection with the exemption request of the real estate transfer tax and the property tax before the Municipality of San Isidro.
Education
Student of the Accounting Degree Program in Universidad Peruana de Ciencias Aplicadas. Lima.
Specialization in Infrastructure Law in School of Graduate Business Administration – ESAN. Lima, 2017.
Specialization in Energy (electric) Law in the Peruvian Mining, Oil and Energy Society. Lima, 2016.
Specialization in Mining Law in the Peruvian Mining, Oil and Energy Society. Lima, 2011.
Specialization in Oil & Gas Law in the Peruvian Mining, Oil and Energy Society. Lima, 2011.
International Tax Law program in Austral University. Buenos Aires, Argentina, 2009.
Diploma in Energy Law in Pontificia Universidad Catolica del Peru, Lima, 2009.
Law Degree by Pontificia Universidad Catolica del Peru, Lima, 2007.
Admission
Callao Bar Association, 2009.
Membership
Peruvian Energy, Oil & Gas and Mining Law Institute (INDEMIPE).
Peruvian Tax Law Institute (IPDT).
International Fiscal Association (IFA).
Additional Information
Experience
Principal Associate in Estudio Echecopar (since September 2014).
Tax Advisor in Repsol (September 2011 - August 2014).
Senior lawyer in Ernst & Young (October 2009 - September 2011).
Senior lawyer in Deloitte & Touche (October 2007 - May 2009).
Lawyer in Estudio Muñiz, Ramirez, Perez Taiman y Olaya (May 2004 - September 2007).
Experience as a trainee in the Tax Administration (SUNAT) and the Tax Court (Tribunal Fiscal).