Dora Ramos

Principal Associate
  • Biography

    Dora is specialized in Tax Law, with experience in advice companies and individuals domiciled and non- domiciled residents in relation to tax planning of their transactions and tax matters regarding the development of their economic activities. Dora has also experience in advice companies in Tax Litigation Procedures.

  • Experience

    • Advised Bancolombia, non-resident entity, in the preparation of a tax basis certification to validate the cost of its credits granted to Peruvian entities. This procedure takes place since Bancolombia wanted to transfer its credits over the nominal value (which is fairly uncommon, but perfectly legal). In our opinion, the gain obtained for the transfer of such credits is not subject to Peruvian Income Tax (it does not qualify as a Peruvian sourced income, therefore, in this case there was not a tax basis that had to be certified. However, due to the lack of a specific regulation regarding the transfer of the credit over the nominal value, Bancolombia defined to adopt a conservative position and request a tax basis certification. 
    • Advised Parque Arauco and some of its subsidiaries in the purchase of 100% of the commercial business integrated by Megaplaza shopping centers. The services provided included the analysis of the tax structure proposed by the sellers, considering the application of the General Antiavoidance Rule (“GAR”). The seller structure included the spin-off of some of the companies and/or assets that were not part of the deal.
    • Advised and represented Baker Hughes in a Tax appeal procedure. In this case, the assessment related to the tax deductions of the payment made by Baker Hughes to its employees that concluded their labour contracts. This was a landmark case since the Peruvian Tax Court changed its previous incorrect criteria, where it concluded that this payment was not deductible for Income Tax purposes if a judicial order was not in place.
    • Supported Empresa General de Capital and Masterville, both of them non-domiciled entities, on a tax basis certification proceeding in order to transfer their shares in San Miguel Industrias PET (Peruvian entity). During the aforementioned procedure, our tax team actively advised and represented them during the tax audit before the Peruvian Tax Administration. The result was favourable, meaning that the Certificate of Invested Capital was obtained under the requested terms.
    • Advised Quimtia and some of its subsidiaries on the tax planning concerning a corporate reorganisation, in order to obtain the most efficient corporate structure with the lower tax cost. The services provided included the analysis of the possible tax structure considering the application of the General Antiavoidance Rule (GAAR”) and the analysis of the best structure not to breach the qualification requirements to be a party to agreements executed with the Peruvian government. Additionally, our tax and corporate team helped QUIMTIA with the implementation of the corporate reorganisations.
    • Advised Glaxosmithkline Peru S.A. in the transfer of all its assets to another company. The assets include movable goods, real estate property, contracts, sales orders, other contractual obligations, inventory and samples (existing and in transit), among others.
    • Advised Grand Success Investment (Singapore) Private Limited (GS) and CFG Investment SAC to recalculate the capital gain tax triggered in Peru upon the indirect transfer of the Copeinca ASA (Norwegian company) shares by Grand Success Investment (Singapore) LTD, after the USA Bankruptcy Court of the Southern District of New York authorised CFG Investment SAC (on behalf of GS) to satisfy an arbitration award in favour of Veramar Azul S.L. for a call option price adjustment.
  • Education

    • Universita di Bologna, Master in Tax Law, Italia, 2012-2013.
    • Universidad Peruana de Ciencias Aplicadas (UPC), Law Degree, Lima, 2010.
    • Law Academic Excellency Awards 2009 "Jose Leon Barandiaran Hart", granted by the Peruvian Government through the National Superintendency of the Public Registry – SUNARP.
    • Universita degli Studi di Pavia, Italy, 2003-2004.

    Admission

    • Lima Bar Association, 2010.

    Membership

    • Member of the Peruvian Institute for Tax Law - IPDT (2011).
    • Member of the International Fiscal Association (IFA) - Peruvian Chapter (2011).
  • Additional Information

    Experience

    • Principal Associate at Estudio Echecopar (since 2017).
    • Senior Associate at Estudio Echecopar (since 2014).
    • Agenzia delle Entrate - Direzione Regionale Emilia Romagna - Stagista (June - September 2013).
    • Senior at Ernst & Young (2011- 2013).
    • Associate at Estudio Echecopar (2010- 2011).

    Teaching experience

    • Teaching Assistant of Tax Law I at Universidad de Lima (2012-2013).
    • Teaching Assistant of Corporate Law II at Universidad Peruana de Ciencias Aplicadas (UPC) - 2008.