Next Generation Partners

Firms To Watch: Tax

Ecija Uruguay opened its offices in April 2023 and draws on its global network to advise on the tax aspects of M&A and corporate transactions. Juan Ignacio Fraschini leads the team, bringing expertise in international tax matters.

Tax in Uruguay

Ferrere

Multinationals regularly seek out Ferrere‘s dedicated tax department for advice on sophisticated tax structures and representation in sensitive tax litigation. The team has a proven success rate before the Administrative Claims Court and the Supreme Court of Justice, obtaining rulings for clients against the Tax Administration. Working in tandem with the firm’s corporate and banking teams, and its offices across Latin America, the group is active in M&A and finance transactions, often on a cross-border basis. The energy and natural resources sectors are particular areas of expertise, and the team handles the tax aspects of wind farms, oil and gas exploration and forestry projects. Practice head Gianni Gutiérrez is an expert in transfer pricing cases and tax optimisation for significant investment projects, as well as successfully defending clients in disputes initiated by the tax authority. As head of the firm’s private client team, Isabel Laventure is well placed to advise on personal wealth planning. María Laura Caffera, senior associate, leads the team’s customs practice, bringing expertise in foreign trade taxation to the team. Also at the senior associate level, Antonella Caraballo is active in both tax and customs matters for national and international clients.

Praxisleiter:

Gianni Gutiérrez


Referenzen

‘Fully fledged tax and tax accounting firm with lots of experience handling cross-border transactions.’

‘Isabel Laventure is a natural leader with full control of all relevant tax and in general legal and business matters. 10+ years sharing projects and professional experience and consistently receiving practical advice, with responses, solutions, alternatives when needed.’

‘Gianni Gutierrez: leads a team of excellence and versatility in all tax areas.’

Kernmandanten

Uber


Hyatt


DirecTV


JPMorgan Chase


JetSmart


Archer Daniels Midland


Hidrovias do Brasil


IBM


Pluspetrol


Colgate Palmolive


Syngenta


UBS


Nestlé


Sabre


British Gas


DEME Group


Essential Energy


Warnermedia Direct Latam


Berlitz


Institut Pasteur


Joint Distribution Committee


Scotiabank Uruguay


Diageo


BASF


Siemens


Kemira


Banco de la República Oriental del Uruguay


Stepan


Infogain


Auckland BioSciences


Novartis


Alfanar Energía


Highlight-Mandate


  • Represented Uber in litigation challenging decrees issued by the Executive Branch that forced the company to pay taxes in Uruguay, and in a case against the Uruguayan Tax Authority for the refund of taxes paid in 2017, decided by the Supreme Court of Justice.
  • Acted as local counsel to the Uruguayan subsidiaries of Hidrovias do Brasil in the context of a $91m secondary offer of shares by institutional investors Patria and Temasek.
  • Advised Aberdeen on tax structuring for the $234m acquisition of participation in the Circuito 3 toll road concession in Uruguay.

Guyer & Regules

With expert knowledge of local regimes, offshore regulation and free trade zones, Guyer & Regules is a go-to firm for tax planning. Providing tax advice in corporate and business matters, the team is active in M&A and restructurings, including spin-offs, liquidations and asset transfers. The team excels in interactions with the tax authorities, representing clients in administrative and judicial disputes and advising on inquiries before the authorities. It counts both onshore and offshore companies among its clients, for which it provides a comprehensive compliance service. Transfer pricing is another prolific area for the department, and it handles customs valuation and related tax controversies. Juan Manuel Albacete leads the team, and his broad tax practice encompasses tax planning and tax restructuring. He is regularly called upon by corporate clients, financial institutions and the Uruguayan government for advice on tax matters, as well as counting a number of clients from the oil and gas sector among his roster. At the senior associate level, Marcelo Marchetti focuses his tax practice on corporate taxation, advising on the tax elements of M&A. Gastón Lapaz specialises in tax disputes, representing clients in both judicial and administrative tax litigation.

Praxisleiter:

Juan Manuel Albacete


Referenzen

‘The G&R firm is characterised by having excellent level professionals who are leaders in the country’s corporate and legal market. Juan M. Albacete, main partner of the tax area, has great prestige and is a mandatory consultation on complex issues.’

‘Juan Albacete is a reference in Uruguay on the matter. His experience and knowledge allow him to provide precise advice immediately. His writings are profound and demonstrate study and dedication. He is always available, even after hours and on weekends. In addition to his outstanding professionalism, his people skills make it a pleasure to work with him.’

‘The team of tax lawyers is very good and cares about my business, my problems. I can safely say that it is the best team I have worked with in Uruguay. The lawyers are exceptional, in particular Marcelo Marchetti stands out, an exceptional lawyer.’

Kernmandanten

Citibank


Itaú Bank


Goldman Sachs & Co


Barclays Capital


BNP Paribas Securities


BBVA


Julius Baer


Heritage


AXION


MERCADO LIBRE


Total No


Emirates


Corporación América


Louis Dreyfus Company


Bunge Agritrade


Cargill


Unilever


Philip Morris (Abal Hnos)


VRG Linhas Aéreas (Gol)


Tyco


Corporación Vial


Asociación de Bancos


Cabify


Parden


Ocean Network


Overactive


Highlight-Mandate


  • Assisted the Chamber of Information Technology in the drafting of a law that was approved by the Congress and the Executive Branch that creates relevant tax incentives for companies to employ non-residents in the technology and software areas.
  • Advised Montes del Plata on a claim for updated repayment of high amounts, claiming interest and updating for the loss of purchasing power of the currency since the day of effective payment.
  • Advising Porto Seguro on a request to the Ministry of Economy for exemption from the income tax on non-residents on the transfer of Porto Seguro – Seguros del Uruguay shares.

Bergstein Abogados

As well as advising multinationals and local businesses, Bergstein Abogados also provides tax advice to individuals and regularly handles wealth management matters. The practice is well placed to advise clients on their interactions with, and defend them before, the tax office; it is regularly sought out by clients for representation in tax litigation. The team has strength in corporate taxation and in-depth knowledge of the tax and transfer pricing implications of restructurings, the establishment of new entities and the expansion of operations. The tax treatment of e-commerce and internet platforms are other specialist areas of expertise, and the team counts technology companies among its clients. Domingo Pereira leads the team, advising an extensive roster of national and international companies on tax planning, wealth management and interactions with the tax office. He also has a wealth of experience representing clients before the Supreme Court of Justice and the High Administrative Court. Jonás Bergstein advises companies on international tax planning, with a background in project finance and M&A. Senior associate Guzmán Ramírez has a proven track record in tax litigation, having participated in high-profile cases.

Praxisleiter:

Domingo Pereira


Kernmandanten

Abbott Laboratories


Cisco Systems


Farmers Insurance


Red Bull Bragantino


Avanade


NTT Data


Deugro


ADP


CEVA Logistics


Mediapro


Highlight-Mandate


  • Advised Abbott Laboratories on the local tax implications of an internal restructuring transaction.
  • Advised Cisco Systems on the tax implications associated with a stock options plan.
  • Advised Farmers Insurance on the taxation, transfer pricing and permanent establishment implications for operating in Uruguay.

Brum Costa Abogados

The financial sector is a key focal point for Brum Costa Abogados, and the tax team counts stockholders, financial advisers and the Montevideo Stock Exchange among its clients. Other prolific areas for the practice include the software and free zone sectors. The team’s strength in tax compliance sees it advise on changes to income tax and beneficial ownership regulations. It also has a successful tax litigation practice, with experience before the Administrative Contentious Court and the Supreme Court. Practice head Leonardo Costa has in-depth expertise in national and international tax regulations, regularly advising public bodies on the drafting of laws and advising on inspections by the tax administration. Associate Florencia Capelli is a name to note, bringing knowledge of free zones taxation to the team.

Praxisleiter:

Leonardo Costa


Referenzen

‘It is a firm that acts with great professionalism and seriousness. The team is very interdisciplinary, and they interact according to the internal organization, they distribute the activities to give them speed, professionalism, independence of opinions, and then do study and in-depth workshops on the topics of each client. A responsible and very correct treatment throughout the process.’

‘In my particular case, the presence of professionals who fully immerse themselves in the cases, being technically excellent professionals, gives me peace of mind that I am very well advised.’

‘Knowledge of our company and activity. The commitment and involvement of the firm with us as clients.’

Kernmandanten

Bolsa de Valores de Montevideo (BVM)


Cámara de Zonas Francas del Uruguay (CZF)


Instituto Nacional de Carnes (INAC)


Laboratorio Tecnológico del Uruguay (LATU)


Fondo Social de la Construcción (FSC)


Distribuidora Uruguaya de Combustibles (DUCSA)


CANOPUS


Bamboo Payments Group (Perdury/Siempre Pago)


More Money Transfers


Ferro Carril Fútbol Club


Highlight-Mandate


  • Assisted Distribuidora Uruguaya de Combustibles (DUCSA) concerning an unconstitutionality action against provincial tax regulation, the main issue of the dispute being the principles of equality and legality in tax law.
  • Represented Laboratorio Tecnológico del Uruguay (LATU) in a case in which two companies claimed the return of the price that LATU charged for services and requested LATU not perform control activities.
  • Advising Ferro Carril Fútbol Club on aspects related to the promotion of a judicial request for collection of undue payment before the tax administration, after winning a lawsuit before the Contentious Administrative Court.

Deloitte Legal

Deloitte S.C. has a balanced contentious and non-contentious tax practice, advising clients on a day-to-day basis, as well as providing representation in tax controversies. The team provides assessments of clients' tax situations and advises on tax business restructuring. It is well positioned to perform tax audits, with an established tax compliance practice. Juan Bonet heads the practice, with a strong background in international taxation and expertise spanning a range of industries, from finance and consumer goods to the energy, aeronautical and automotive sectors. Senior associate Guillermo Lorbeer offers a tax perspective on M&A, advising on both the buy and sell side of transactions.

Praxisleiter:

Juan Bonet


Referenzen

‘It’s a good team. It has quality and a vocation for client service.’

‘Juan Bonet really masters the CRS topic and knows the regulator, both things combined are very valuable.’

Kernmandanten

InterEnergy Holdings


Pluspetrol


Cabify


Fanapel


Mapfre


Canarias (Yerba Mate)


República Negocios Fiduciarios AFISA


Enrique Quinteros


Kielder


Alicorp


Highlight-Mandate


  • Advised InterEnergy on the process of due diligence and the structuring and closing of the acquisition of the wind farm Solis de Mataojo.
  • Advising Canarias on the relevant asset recovery procedures to enforce the Supreme Court ruling in two high-profile cases regarding the enforcement of certain local taxes.
  • Advised Kielder on all tax matters related to the acquisition of a real estate asset.

Dentons Jiménez de Aréchaga

Working in tandem with its global network of offices, Dentons Jiménez de Aréchaga‘s tax team advises an impressive roster of multinational companies, as well as both new and established companies in Uruguay. The practice specialises in business structuring and tax planning, particularly for clients looking to expand into Uruguay. It also advises on the tax aspects of reorganisations, restructurings and M&A, and the technology sector has also been an increasing area of focus for the team. Julio López heads the team and leads on all tax matters. Senior associate Martin Montoro is a key member of the group, focusing his practice on corporate tax matters and the tax aspects of investments. He also brings international experience to the team, handling foreign trade matters and taxation of international investments and projects.

Praxisleiter:

Julio López


Referenzen

‘In the tax part, the participation of Martín Montoro is very important, as he leads a team of several lawyers to reconcile the work that links labour with commercial and, above all, tax matters where there are different alternatives depending on where in the country the sales are made, and the different tax requirements throughout the marketing chain.’

‘Team with vast knowledge in the infrastructure and energy industry, supporting us in important projects in Uruguay.’

‘Martin Montoro: versatility of topics on which he offers advice, researching and putting on the table aspects that are not visible at first glance, which help in decision-making on our side as a client.’

Kernmandanten

Santander


Mondelēz


Google


Arcos Dorados


Viscofan


PepsiCo


Marfrig


Quantik


Cargo Line


Highlight-Mandate


  • Assisting Cargo Line with the tax aspects of the operation of a new port terminal to be constructed in the Uruguay River coastline.
  • Assisted a subsidiary of Arcos Dorados with the tax impacts arising from recent changes to the taxation rules for foreign-sourced passive income of multinational enterprises in Uruguay, which entered into effect on January 1st, 2023.
  • Assisted a subsidiary of Marfrig Group on the tax impact arising from a corporate reorganisation plan, which entailed a parent-subsidiary downstream merger for which there are no clear tax rulings.

Hughes & Hughes

Hughes & Hughes‘ tax team has a strong background in advising companies on the establishment and expansion of operations in Uruguay. It advises on corporate and tax structures for infrastructure projects, investments and commercial, industrial and services activities in the country. Tax audits and tax litigation are other prolific areas for the team, which also advises on the application of double tax treaties. Alejandro Horjales is head of the tax, outsourcing and transfer pricing team, supported by Haroldo Espalter, who advises international clients on foreign investment and the development of operations in Uruguay. Associate and certified public account Miguel Rocca co-leads the tax team, specialising in tax planning on behalf of both national and international clients. Magela Ramon, associate, brings public sector experience at the National Tax Office to the team and advises on foreign trade.

Praxisleiter:

Haroldo Espalter; Alejandro Horjales


Referenzen

‘A good firm, with great professionals.’

‘Its partners show great availability for each requirement and good quality in the work carried out.’

Kernmandanten

Surinor (Pestana Group)


Afry Group – Poyry


Urumix


Balsa & Asociados – Danilum


Novartis


Adidas


Fresenius Medical Care


Lojas Renner


Highlight-Mandate


  • Advising Afry Group-af Poyry on the relevant tax aspects of the installation under the general tax regime and the free zone regime, in order to operate in Uruguay.
  • Advising Surinor on all the relevant tax aspects of its installation in Uruguay and advising the company on tax matters, such as administrative procedures.
  • Advising Premezclados Uruguay on its aquisition by Saint-Gobain, together with its brand URUMIX.

Bragard Abogados

Bragard Abogados provides day-to-day tax advice to clients across a range of industries, including the technology, media and energy sectors. The team also participates in tax due diligence processes, as well as advising clients on fiscal strategy. Jean Jacques Bragard heads the team, alongside Agustina Bomio, who strengthens the practice’s global capabilities, bringing in-depth expertise in international tax. Cynthia Carballo is also an active member of the team.

Praxisleiter:

Agustina Bomio; Jean Jacques Bragard


Kernmandanten

Grupo DISA


Grupo SURA


El Observador


Estudio Gomez Platero


Crédito Amigo


Servimedic


Highlight-Mandate


  • Advised DISA Group on an action of unconstitutionality brought against a tax that taxes companies that own or ship fuel at the rate of 1% of the sale price.
  • Advised on the sale of El Observador, participating in the tax due diligence and advising on the tax aspects of expansion to other countries.
  • Providing day-to-day tax support to general counsel of Grupo SURA in Uruguay.

Hessdörfer Tax & Corporate

Since its foundation in April 2023, Hessdörfer Tax & Corporate has been advising a growing list of local and international clients on tax matters. The specialised boutique also provides local advice on tax matters to mid-size firms. Founding partner Andrés Hessdörfer has a wealth of expertise in tax regulations, business structuring and tax planning, as well as experience in tax disputes at the administrative and jurisdictional levels.

Praxisleiter:

Andrés Hessdörfer


Referenzen

‘The Hessdörfer team goes beyond providing excellent professional service. Their knowledge, updating and network of contacts mean that they are always ahead of the game.’

‘Andrés Hessdörfer is the main partner and the one who gives his mark to the firm. Their professionalism, academic level and predisposition are above average.’

‘Personalised attention with great focus.’

Kernmandanten

Jars Labs


Grupo Fiancar


Element14


Highlight-Mandate


  • Advised Jars Capital on the tax aspects of the acquisition of a prominent Uruguayan software factory, element14.