Mexico

August 16, 2017

Luis Carbajo
	Baker & McKenzie Abogados, S.C. Edificio Virreyes, Pedregal 24, 12th Floor Lomas Virreyes / Col. Molino del Rey 11040 Mexico City Mexico Tel: +52 55 5351 4116 Email: luis.carbajo-martinez@bakermckenzie.com Website: www.bakermckenzie.com Luis Carbajo is the head of the Mexican Baker McKenzie's tax practice group. He is currently located in Mexico City, where he advises multinationals on international tax planning, M&A, cross-border transactions and other business issues. He is a member of the firm's Latin America regional tax steering committee, and an adviser to the tax committee of the National Maquiladora Council. Luis frequently writes tax articles in Tax Notes International and the Practical Mexican Tax Strategies magazine. He also speaks at various seminars organised by CANIETI, CANACINTRA, Tax Executives Institute, Executive Enterprise Institute, Cámara de Comercio de Bogotá and the local Maquiladora associations across Mexico. Luis is a former member of the management committee of the Mexican offices of Baker McKenzie. Luis focuses his practice on litigating and lobbying highly complex issues in the energy sector. He has extensive experience advising on permanent establishment issues, inter-company pricing, taxation of non-resident entities and individuals, and other corporate and tax matters such as VAT, assets tax, planning and litigation on social security contributions, and local and municipal taxes. His practice also covers tax planning and transfer pricing, particularly in the energy sector. He is a member of the Texas-Mexico Bar, Harvard Law School Alumni Association, Mexican National Association of Corporate Counsel, International Fiscal Association and Mexican Institute of Finance Executives. Luis was admitted to the Mexico bar in 1993. He gained his JD from the University of Guanajuato in 1995, a joint degree international tax programme/LLM from the Harvard Law School in 1995, and a certificate in special studies of administration and management from Harvard University in 1994.

Luis Carbajo

Baker & McKenzie Abogados, S.C.

Edificio Virreyes, Pedregal 24, 12th Floor

Lomas Virreyes / Col. Molino del Rey

11040 Mexico City

Mexico

Tel: +52 55 5351 4116

Email: luis.carbajo-martinez@bakermckenzie.com

Website: www.bakermckenzie.com

Luis Carbajo is the head of the Mexican Baker McKenzie's tax practice group. He is currently located in Mexico City, where he advises multinationals on international tax planning, M&A, cross-border transactions and other business issues. He is a member of the firm's Latin America regional tax steering committee, and an adviser to the tax committee of the National Maquiladora Council. Luis frequently writes tax articles in Tax Notes International and the Practical Mexican Tax Strategies magazine. He also speaks at various seminars organised by CANIETI, CANACINTRA, Tax Executives Institute, Executive Enterprise Institute, Cámara de Comercio de Bogotá and the local Maquiladora associations across Mexico. Luis is a former member of the management committee of the Mexican offices of Baker McKenzie.

Luis focuses his practice on litigating and lobbying highly complex issues in the energy sector. He has extensive experience advising on permanent establishment issues, inter-company pricing, taxation of non-resident entities and individuals, and other corporate and tax matters such as VAT, assets tax, planning and litigation on social security contributions, and local and municipal taxes. His practice also covers tax planning and transfer pricing, particularly in the energy sector.

He is a member of the Texas-Mexico Bar, Harvard Law School Alumni Association, Mexican National Association of Corporate Counsel, International Fiscal Association and Mexican Institute of Finance Executives.

Luis was admitted to the Mexico bar in 1993. He gained his JD from the University of Guanajuato in 1995, a joint degree international tax programme/LLM from the Harvard Law School in 1995, and a certificate in special studies of administration and management from Harvard University in 1994.

Martha Dorantes
	Deloitte Mexico Mexico City Tel: +55 (55) 50806425 Email: mdorantes@deloittemx.com Website: www.deloitte.com Martha Dorantes, Deloitte Mexico, is a partner in the business tax and legal department. She has been with Deloitte Mexico since 2014 after 14 years of practice as associated in a leading Mexico City boutique tax law firm. Her principal area of expertise is tax consulting, tax controversy and tax litigation, related to the financial sector, as well as regulatory aspects of the same. She has 17 years of experience in trial law related to complex tax matters. Martha studied law at the Anahuac University. She has a degree in tax law from the Panamericana University and she is a member of the Mexican Lawyers Bar Association.

Martha Dorantes

Deloitte Mexico

Mexico City

Tel: +55 (55) 50806425

Email: mdorantes@deloittemx.com

Website: www.deloitte.com

Martha Dorantes, Deloitte Mexico, is a partner in the business tax and legal department. She has been with Deloitte Mexico since 2014 after 14 years of practice as associated in a leading Mexico City boutique tax law firm. Her principal area of expertise is tax consulting, tax controversy and tax litigation, related to the financial sector, as well as regulatory aspects of the same. She has 17 years of experience in trial law related to complex tax matters.

Martha studied law at the Anahuac University. She has a degree in tax law from the Panamericana University and she is a member of the Mexican Lawyers Bar Association.

Ricardo González Orta
	Deloitte Mexico Paseo de la Reforma 505 Col Cuauhtémoc 06500 México, DF Mexico Tel: +52 55 50 80 70 23 Fax: +52 55 50 80 60 01 Email: rgonzalezorta@deloittemx.com Website: www.deloitte.com/mx Ricardo González Orta, Deloitte Mexico, is a partner and leader of the tax and legal practice. He is also the business tax leader for Deloitte member firms in Latin America. Ricardo is based in the Mexico City office where he advises multinational enterprises on tax-related matters, including: controversy issues with tax authorities on domestic and international matters, structuring new businesses, acquisitions, reorganisations, joint ventures, double taxation issues and transfer pricing. Ricardo is the former leader of the Deloitte Mexico business tax practice and, from 2001 to 2010, served as the Latin American transfer pricing leader for Deloitte member firms in the region, as well as being the Deloitte Mexico transfer pricing leader. Before joining Deloitte, Ricardo spent eight years in a number of top executive posts with the Ministry of Finance and the Mexican Tax Administration Service. From July 1999 to November 2000, Ricardo was general director of tax and customs policy at the Under Ministry of Income, where his duties included designing tax and customs policy. In this position, he negotiated the Mexico-US intergovernmental transfer-pricing agreement in the maquiladora industry. Before this, he acted as general director of legislation and international negotiations (1998 to 1999), where his main functions included: drafting tax and customs legislation, negotiating double-taxation treaties, and representing the Mexican government in international forums (especially OECD). From March to June 1998, he was general director of international tax affairs at the Tax Administration Service (formerly Under Ministry of Income of the Ministry of Finance and Public Credit). Primary responsibilities included: transfer-pricing audits, the negotiations of advance pricing agreements (APAs), the issuance of private letter rulings regarding foreign residents with Mexican source income, the exchange of tax and customs information with other countries and the performance of audits and issuance of rulings in line with Mexico's free trade agreements. Before this, he was assistant general director for international audits (1993 to 1998). In this position, Ricardo created the international audit programme, which included: transfer pricing inspections, negotiating APAs, drafting the 1997 tax reform on transfer pricing, the inspection of international transactions, audits of origin pursuant to Mexico's commercial agreements, acting as competent authority for the exchange of tax and customs information, and inspection of Mexican residents with investments in low-tax jurisdictions. Ricardo graduated from Universidad Iberoamericana. Ricardo is a frequent speaker in different national and international forums. He writes periodically for the International Management Tax Journal on domestic and international topics. For almost a decade he has been named by Euromoney as a leading transfer pricing and tax adviser.

Ricardo González Orta

Deloitte Mexico

Paseo de la Reforma 505

Col Cuauhtémoc

06500 México, DF

Mexico

Tel: +52 55 50 80 70 23

Fax: +52 55 50 80 60 01

Email: rgonzalezorta@deloittemx.com

Website: www.deloitte.com/mx

Ricardo González Orta, Deloitte Mexico, is a partner and leader of the tax and legal practice. He is also the business tax leader for Deloitte member firms in Latin America. Ricardo is based in the Mexico City office where he advises multinational enterprises on tax-related matters, including: controversy issues with tax authorities on domestic and international matters, structuring new businesses, acquisitions, reorganisations, joint ventures, double taxation issues and transfer pricing. Ricardo is the former leader of the Deloitte Mexico business tax practice and, from 2001 to 2010, served as the Latin American transfer pricing leader for Deloitte member firms in the region, as well as being the Deloitte Mexico transfer pricing leader.

Before joining Deloitte, Ricardo spent eight years in a number of top executive posts with the Ministry of Finance and the Mexican Tax Administration Service.

From July 1999 to November 2000, Ricardo was general director of tax and customs policy at the Under Ministry of Income, where his duties included designing tax and customs policy. In this position, he negotiated the Mexico-US intergovernmental transfer-pricing agreement in the maquiladora industry. Before this, he acted as general director of legislation and international negotiations (1998 to 1999), where his main functions included: drafting tax and customs legislation, negotiating double-taxation treaties, and representing the Mexican government in international forums (especially OECD).

From March to June 1998, he was general director of international tax affairs at the Tax Administration Service (formerly Under Ministry of Income of the Ministry of Finance and Public Credit). Primary responsibilities included: transfer-pricing audits, the negotiations of advance pricing agreements (APAs), the issuance of private letter rulings regarding foreign residents with Mexican source income, the exchange of tax and customs information with other countries and the performance of audits and issuance of rulings in line with Mexico's free trade agreements. Before this, he was assistant general director for international audits (1993 to 1998). In this position, Ricardo created the international audit programme, which included: transfer pricing inspections, negotiating APAs, drafting the 1997 tax reform on transfer pricing, the inspection of international transactions, audits of origin pursuant to Mexico's commercial agreements, acting as competent authority for the exchange of tax and customs information, and inspection of Mexican residents with investments in low-tax jurisdictions.

Ricardo graduated from Universidad Iberoamericana.

Ricardo is a frequent speaker in different national and international forums. He writes periodically for the International Management Tax Journal on domestic and international topics. For almost a decade he has been named by Euromoney as a leading transfer pricing and tax adviser.

Mauricio Martinez-D’Meza
	Deloitte Mexico Paseo de la Reforma 489, Piso 6 Col. Cuauhtémoc 06500, México Mexico Direct: +52 (55)5080-7040 Fax: +52 (55)5080-6931 Email: maumartinez@deloittemx.com Website: www.deloitte.com Mauricio Martinez-D'Meza, Deloitte Mexico, has been a business tax partner since October 2002. His areas of expertise include domestic and international tax planning, tax controversy and tax litigation. He is the leader of the tax controversy practice in Mexico and of the legal services for the LATAM region. He served for nine years in the Ministry of Finance prior to joining Deloitte as assistant chief counsel for large taxpayers, assistant general director for international tax policy and treaty negotiations and assistant chief counsel for domestic taxes. From 1999–01, he was a partner at Baker McKenzie in Monterrey. From 1995-97, he served as representative for the Ministry of Finance before the US and Canadian governments for tax and customs affairs in Washington, DC. He got his bachelor's law degree in 1993 from the Autonomous Technological Institute of México (ITAM). He holds a postgraduate degree from Harvard-ITAM (international taxation programme). Mauricio has taught in several universities including the Monterrey Institute of Technology and Higher Education (2010-current) postgraduate degree in taxes – litigation and defence processes, North Anahuac University: Tax Law II (June 1999) and political history (1998); Ibeoamerican University: tax law (1998); ITAM: Mexican taxation (1995).

Mauricio Martinez-D’Meza

Deloitte Mexico

Paseo de la Reforma 489, Piso 6

Col. Cuauhtémoc

06500, México

Mexico

Direct: +52 (55)5080-7040

Fax: +52 (55)5080-6931

Email: maumartinez@deloittemx.com

Website: www.deloitte.com

Mauricio Martinez-D'Meza, Deloitte Mexico, has been a business tax partner since October 2002. His areas of expertise include domestic and international tax planning, tax controversy and tax litigation. He is the leader of the tax controversy practice in Mexico and of the legal services for the LATAM region.

He served for nine years in the Ministry of Finance prior to joining Deloitte as assistant chief counsel for large taxpayers, assistant general director for international tax policy and treaty negotiations and assistant chief counsel for domestic taxes. From 1999–01, he was a partner at Baker McKenzie in Monterrey. From 1995-97, he served as representative for the Ministry of Finance before the US and Canadian governments for tax and customs affairs in Washington, DC.

He got his bachelor's law degree in 1993 from the Autonomous Technological Institute of México (ITAM). He holds a postgraduate degree from Harvard-ITAM (international taxation programme).

Mauricio has taught in several universities including the Monterrey Institute of Technology and Higher Education (2010-current) postgraduate degree in taxes – litigation and defence processes, North Anahuac University: Tax Law II (June 1999) and political history (1998); Ibeoamerican University: tax law (1998); ITAM: Mexican taxation (1995).

Jorge Narváez-Hasfura
	Baker & McKenzie Abogados, S.C. Edificio Virreyes, Pedregal 24, 12th Floor Lomas Virreyes / Col. Molino del Rey 11040 Mexico City Mexico Tel: +52 55 5279 2924 Mobile: +52 (1) 55 4343 7262 Email: jorge.narvaez-hasfura@bakermckenzie.com Website: www.bakermckenzie.com With 30 years of experience, Jorge Narvaez-Hasfura has been voted as a leading tax practitioner in Mexico on tax litigation, transfer pricing and indirect taxation by the International Tax Review. He has been nominated to appear in the guide to the world's leading transfer pricing advisers. He has been voted as one of the leading tax practitioners in Mexico by Chambers & Partners every year since 2011 and praised by well-known international publications for his transfer pricing and corporate reorganisation work alongside his very strong practice in tax rulings, tax treaties and tax litigation. As of October 2014, he has been chairing the global tax dispute resolution group of Baker McKenzie. Formerly, he has acted as chair of the Latin American tax practice group and member of the global tax steering committee of Baker McKenzie, as well as member of the global transfer pricing sub-group of Baker McKenzie and chair of the Latin American value added tax practice group and member of the global value added tax steering committee of Baker McKenzie. As of October 2013, he was appointed as member of the global financial committee of Baker McKenzie, representing the Latin American region. He is founder member of the Legislative Tax Analysis Group (ATRIL), and in March 2012 he was appointed by the Mexican President for a four-year term as honorary independent adviser and member of the sounding board of the Mexican Taxpayers' Ombudsman (the PRODECON). Also, early this year he wrote the foreword for the book entitled 'Taxpayers Rights in a Transparent and Global Society', which was globally published by the PRODECON. Jorge's areas of his expertise include corporate income tax (Mexico), transfer pricing, international tax planning, corporate reorganisations (Mexico), tax rulings, tax treaties, personal income tax (Mexico), tax Litigation (Mexico), estate planning, wealth management and VAT (Mexico). He is a member of Mexican Bar Association's tax committee. He is also a member of the International Bar Association, International Fiscal Association, British Chamber of Commerce of Mexico, and the Canadian Chamber of Commerce of Mexico. Jorge was admitted to the Mexican bar in 1987. He gained his JD from Escuela Libre de Derecho, his LLM from the University of Notre Dame, and diplomas in tax law and taxes from the Autonomous Technological Institute of Mexico (ITAM). Jorge also has a diploma on tax policy and administration from the John F Kennedy School of Government at Harvard University. He has also pursued studies at the International Bureau of Fiscal Documentation.

Jorge Narváez-Hasfura

Baker & McKenzie Abogados, S.C.

Edificio Virreyes, Pedregal 24, 12th Floor

Lomas Virreyes / Col. Molino del Rey

11040 Mexico City

Mexico

Tel: +52 55 5279 2924

Mobile: +52 (1) 55 4343 7262

Email: jorge.narvaez-hasfura@bakermckenzie.com

Website: www.bakermckenzie.com

With 30 years of experience, Jorge Narvaez-Hasfura has been voted as a leading tax practitioner in Mexico on tax litigation, transfer pricing and indirect taxation by the International Tax Review. He has been nominated to appear in the guide to the world's leading transfer pricing advisers. He has been voted as one of the leading tax practitioners in Mexico by Chambers & Partners every year since 2011 and praised by well-known international publications for his transfer pricing and corporate reorganisation work alongside his very strong practice in tax rulings, tax treaties and tax litigation.

As of October 2014, he has been chairing the global tax dispute resolution group of Baker McKenzie. Formerly, he has acted as chair of the Latin American tax practice group and member of the global tax steering committee of Baker McKenzie, as well as member of the global transfer pricing sub-group of Baker McKenzie and chair of the Latin American value added tax practice group and member of the global value added tax steering committee of Baker McKenzie. As of October 2013, he was appointed as member of the global financial committee of Baker McKenzie, representing the Latin American region.

He is founder member of the Legislative Tax Analysis Group (ATRIL), and in March 2012 he was appointed by the Mexican President for a four-year term as honorary independent adviser and member of the sounding board of the Mexican Taxpayers' Ombudsman (the PRODECON). Also, early this year he wrote the foreword for the book entitled 'Taxpayers Rights in a Transparent and Global Society', which was globally published by the PRODECON.

Jorge's areas of his expertise include corporate income tax (Mexico), transfer pricing, international tax planning, corporate reorganisations (Mexico), tax rulings, tax treaties, personal income tax (Mexico), tax Litigation (Mexico), estate planning, wealth management and VAT (Mexico).

He is a member of Mexican Bar Association's tax committee. He is also a member of the International Bar Association, International Fiscal Association, British Chamber of Commerce of Mexico, and the Canadian Chamber of Commerce of Mexico.

Jorge was admitted to the Mexican bar in 1987. He gained his JD from Escuela Libre de Derecho, his LLM from the University of Notre Dame, and diplomas in tax law and taxes from the Autonomous Technological Institute of Mexico (ITAM). Jorge also has a diploma on tax policy and administration from the John F Kennedy School of Government at Harvard University. He has also pursued studies at the International Bureau of Fiscal Documentation.

Carlos Alberto Ramirez Larsen
	Deloitte Mexico Monterrey Tel: +52 (81) 81 33 74 23 Fax: +52 (81) 81 33 73 83 Email: cramirezlarsen@deloittemx.com Website: www.deloitte.com Carlos Alberto Ramírez Larsen, Deloitte Mexico, is an attorney in law, by the Instituto Tecnológico y de Estudios Superiores de Monterrey, Campus Monterrey, and has a master's degree in tax laws from the Autonomous University of Nuevo León. He has been a tax controversy partner since June 2016. His career in Deloitte started in 2003, when he graduated from the university and, before that, he started practicing in tax law while working in the Federal Tax Court. His areas of expertise include tax litigation, tax controversy, and tax planning. Regarding tax controversy and litigation, Carlos is a highly-skilled lawyer with wide experience in the different types of trials and in negotiations through conclusive agreements before the Procuraduría de la Defensa del Contribuyente. His experience covers a wide range of industries. Currently, he is a professor in the master of tax laws programme in private institutes in Mexico, teaching the assignatures of tax litigation, law interpretation and argumentation and the general theory for taxation – Mexican Tax Code. He is a member of the fiscal committee of the Certified Public Accountant Institute of Nuevo León and the Mexican Lawyers Bar. Inside Deloitte, he is a member of the national tax technical committee, the national tax innovation committee, and the national tax litigation committee. He brings more than 14 years of specialised experience in federal and local tax litigation practice, including taxation, customs and social security.

Carlos Alberto Ramirez Larsen

Deloitte Mexico

Monterrey

Tel: +52 (81) 81 33 74 23

Fax: +52 (81) 81 33 73 83

Email: cramirezlarsen@deloittemx.com

Website: www.deloitte.com

Carlos Alberto Ramírez Larsen, Deloitte Mexico, is an attorney in law, by the Instituto Tecnológico y de Estudios Superiores de Monterrey, Campus Monterrey, and has a master's degree in tax laws from the Autonomous University of Nuevo León. He has been a tax controversy partner since June 2016. His career in Deloitte started in 2003, when he graduated from the university and, before that, he started practicing in tax law while working in the Federal Tax Court. His areas of expertise include tax litigation, tax controversy, and tax planning. Regarding tax controversy and litigation, Carlos is a highly-skilled lawyer with wide experience in the different types of trials and in negotiations through conclusive agreements before the Procuraduría de la Defensa del Contribuyente. His experience covers a wide range of industries. Currently, he is a professor in the master of tax laws programme in private institutes in Mexico, teaching the assignatures of tax litigation, law interpretation and argumentation and the general theory for taxation – Mexican Tax Code. He is a member of the fiscal committee of the Certified Public Accountant Institute of Nuevo León and the Mexican Lawyers Bar. Inside Deloitte, he is a member of the national tax technical committee, the national tax innovation committee, and the national tax litigation committee. He brings more than 14 years of specialised experience in federal and local tax litigation practice, including taxation, customs and social security.

Eduardo Revilla
	Deloitte Mexico Mexico City Tel: +52 (55) 50806081 Email: erevilla@deloittemx.com Website: www.deloitte.com Eduardo Revilla, Deloitte Mexico, studied law at the Free School of Law and was admitted to practice in 1987. For seven years, he worked at the Ministry of Finance of Mexico as director general for international fiscal affairs, deputy federal tax attorney for tax litigation, representative of the Ministry of Finance in Washington, DC, and legal director for tax policy affairs. He chaired some tax expert groups at the committee of fiscal affairs at the OECD and represented Mexico in several tax treaty negotiations and customs and trade arrangements (i.e. NAFTA). In 1998, he joined as partner of Calvo, González Luna, Moreno y Revilla (previously known as González Luna y Pérez de Acha). In 2008, he co-founded his own law firm Revilla y Álvarez Alcalá. In September 2016, he joined Deloitte in Mexico City. He has taught tax law for nearly 30 years and currently teaches at the Autonomous Technological Institute of Mexico. He has written for several publications on tax matters in Mexico and in the US. He writes a bi-weekly column for the El Economista in Mexico City.

Eduardo Revilla

Deloitte Mexico

Mexico City

Tel: +52 (55) 50806081

Email: erevilla@deloittemx.com

Website: www.deloitte.com

Eduardo Revilla, Deloitte Mexico, studied law at the Free School of Law and was admitted to practice in 1987. For seven years, he worked at the Ministry of Finance of Mexico as director general for international fiscal affairs, deputy federal tax attorney for tax litigation, representative of the Ministry of Finance in Washington, DC, and legal director for tax policy affairs. He chaired some tax expert groups at the committee of fiscal affairs at the OECD and represented Mexico in several tax treaty negotiations and customs and trade arrangements (i.e. NAFTA).

In 1998, he joined as partner of Calvo, González Luna, Moreno y Revilla (previously known as González Luna y Pérez de Acha). In 2008, he co-founded his own law firm Revilla y Álvarez Alcalá. In September 2016, he joined Deloitte in Mexico City. He has taught tax law for nearly 30 years and currently teaches at the Autonomous Technological Institute of Mexico. He has written for several publications on tax matters in Mexico and in the US. He writes a bi-weekly column for the El Economista in Mexico City.

Hugo Romero
	Deloitte Mexico Paseo de la Reforma No. 505, piso 23 Colonia Cuauhtémoc C.P. 06500, Mexico City Mexico Tel: +52 (55) 5080 6331 Fax: +52 (55) 5080 6001 Email: hromero@deloittemx.com Website: www.deloitte.com Hugo Romero, Deloitte Mexico, is a partner in the tax litigation department. He has been with Deloitte Mexico for nine years. His principal area of expertise is tax litigation. He has 19 years of experience in trial law related to complex tax matters. He has helped clients challenge the constitutionality of tax laws setting national judicial precedents. In the past three years his success ratio in tax cases involving interpretation of legal provisions where he has been the partner in charge has been 90%. Hugo has been a speaker in many conferences regarding tax matters, including the Eight Latin-American Congress of the International Fiscal Association, the Mexican Lawyers Bar Association and the Public Accountants Association of Mexico. Hugo has written several articles on tax and procedural topics, which have been published in leading Mexican tax publications. Hugo studied law at the Iberoamericana University in Mexico City (the eighth semester was coursed at the University of North Carolina at Chapel Hill, US). He later was certified by the Judicial Law School with a degree in constitutional matters. He graduated with a master's degree in tax law from the Pan America University. He later completed another qualification from Sheltons SITTI in international taxation principles and planning. Finally, he obtained a degree in financial administration from the Pan America University. He also has a degree in Mexican history. Hugo is a member of the Mexican Lawyers Bar Association and the International Fiscal Association Chapter Mexico.

Hugo Romero

Deloitte Mexico

Paseo de la Reforma No. 505, piso 23

Colonia Cuauhtémoc

C.P. 06500, Mexico City

Mexico

Tel: +52 (55) 5080 6331

Fax: +52 (55) 5080 6001

Email: hromero@deloittemx.com

Website: www.deloitte.com

Hugo Romero, Deloitte Mexico, is a partner in the tax litigation department. He has been with Deloitte Mexico for nine years. His principal area of expertise is tax litigation. He has 19 years of experience in trial law related to complex tax matters. He has helped clients challenge the constitutionality of tax laws setting national judicial precedents. In the past three years his success ratio in tax cases involving interpretation of legal provisions where he has been the partner in charge has been 90%.

Hugo has been a speaker in many conferences regarding tax matters, including the Eight Latin-American Congress of the International Fiscal Association, the Mexican Lawyers Bar Association and the Public Accountants Association of Mexico.

Hugo has written several articles on tax and procedural topics, which have been published in leading Mexican tax publications.

Hugo studied law at the Iberoamericana University in Mexico City (the eighth semester was coursed at the University of North Carolina at Chapel Hill, US). He later was certified by the Judicial Law School with a degree in constitutional matters. He graduated with a master's degree in tax law from the Pan America University. He later completed another qualification from Sheltons SITTI in international taxation principles and planning. Finally, he obtained a degree in financial administration from the Pan America University. He also has a degree in Mexican history.

Hugo is a member of the Mexican Lawyers Bar Association and the International Fiscal Association Chapter Mexico.

Ricardo Santoyo
	Deloitte México Paseo de la Reforma 505 Cuauhtémoc, 06500, Mexico City Mexico Tel: +52 (55) 50807041 Email: risantoyo@deloittemx.com Website: www.deloitte.com Ricardo Santoyo, Deloitte Mexico, has been a tax controversy partner since June 2017, specialising in consulting and litigation services in tax and customs matters. In charge of the foreign trade and customs litigation teams, Ricardo has been part of important controversies between taxpayers and customs authorities in administrative and judicial proceedings. His experience and knowledge in tax and customs subjects has enabled him to help build strategies to reduce tax burdens for important international groups. His experience is focused on developing negotiation strategies with tax and customs authorities, filing legal actions and alternative defences for the solution of controversies, according to each case. With more than 17 years of experience in tax/customs litigation and consulting, Ricardo has taught at the Valley of Mexico University (Universidad del Valle de México) and has published articles in magazines and specialised communication media. He has a law degree from La Salle del Pedregal University, with a master's degree in strategic business consulting from Panamerican University (Universidad Panamericana) and a master's degree in business and international trade from de las Americas University Mexico City. In the summer of 2006, he assisted the international public and private law seminar organied by the International Law Academy of The Hague, in the Netherlands. Ricardo is a partner of the Mexican Bar Association and is part of the tax and foreign trade committees, as well as an active partner of the National Association of Company Attorneys and the American Chamber of Commerce of Mexico.

Ricardo Santoyo

Deloitte México

Paseo de la Reforma 505

Cuauhtémoc, 06500, Mexico City

Mexico

Tel: +52 (55) 50807041

Email: risantoyo@deloittemx.com

Website: www.deloitte.com

Ricardo Santoyo, Deloitte Mexico, has been a tax controversy partner since June 2017, specialising in consulting and litigation services in tax and customs matters.

In charge of the foreign trade and customs litigation teams, Ricardo has been part of important controversies between taxpayers and customs authorities in administrative and judicial proceedings. His experience and knowledge in tax and customs subjects has enabled him to help build strategies to reduce tax burdens for important international groups.

His experience is focused on developing negotiation strategies with tax and customs authorities, filing legal actions and alternative defences for the solution of controversies, according to each case.

With more than 17 years of experience in tax/customs litigation and consulting, Ricardo has taught at the Valley of Mexico University (Universidad del Valle de México) and has published articles in magazines and specialised communication media.

He has a law degree from La Salle del Pedregal University, with a master's degree in strategic business consulting from Panamerican University (Universidad Panamericana) and a master's degree in business and international trade from de las Americas University Mexico City.

In the summer of 2006, he assisted the international public and private law seminar organied by the International Law Academy of The Hague, in the Netherlands.

Ricardo is a partner of the Mexican Bar Association and is part of the tax and foreign trade committees, as well as an active partner of the National Association of Company Attorneys and the American Chamber of Commerce of Mexico.

Simón Somohano
	Deloitte Mexico Río Lerma No. 232 Piso 9 C.P. 06500, Ciudad de Mexico Mexico Tel: + 52 (664) 622-7872 Email: ssomohano@deloittemx.com Website: www.deloitte.com Simón Somohano, Deloitte Mexico (Galaz, Yamazaki, Ruiz Urquiza, SC), is a tax partner based in Mexico City and Tijuana responsible for the transfer pricing practice in Latin America and the Caribbean region. He has more than 26 years of experience in the application of tax, economic and financial criteria in transfer pricing, anti-dumping/subsidy investigations, valuation analysis of intangibles, double tax treating issues, planning, business model optimisation, structuring and economic consulting. Under his leadership, Deloitte's regional transfer pricing practice has been consistently recognised as one of the leading practices in Latin America, including winning the 2016 award for Mexico Transfer Pricing Firm of the Year from International Tax Review. He has consistently been named as one of the world's leading transfer pricing advisers by the prestigious Transfer Pricing Expert Guide published by Euromoney/Legal Media Group. His clients include several Fortune 500 multinational companies doing business in Mexico. He has extensive experience and a successful track record leading the Mexican negotiations of advanced pricing agreements (APA); mutual agreement procedures (MAP) and transfer pricing examinations with Mexican and foreign authorities, teaming with colleagues in Deloitte's global transfer pricing network. In this venue, Simón led the technical and economic team that successfully obtained in 2016 a hallmark resolution on a transfer pricing dispute through the recently introduced alternative dispute resolution procedure: conclusive agreement. Simón advises in a variety of industry sectors, mainly automotive, manufacturing and maquiladoras, retail and consumer goods, real estate, technology, and the energy and resources market. He also provides specialised counselling to clients in several anti-dumping and subsidy investigations. Simón is a frequent guest speaker in international business forums in Mexico and abroad. He has authored various articles on transfer pricing in specialised journals and is a co-author of the Transfer Pricing International Handbook, A Country-by-Country Guide published by the International Tax Institute and Transfer Pricing, and A Theoretical, Legal and Practice Framework, published by the Institute of Chartered Accountants (Mexico). His professional accreditations and affiliations include being a board member of the transfer pricing committee of the Institute of Chartered Accountants. In addition, as the lead transfer pricing adviser to the National Export Manufacturing and Maquiladora Council (INDEX), Simón has lead the technical negotiations for the establishment of a transfer pricing methodology applicable to about 700 Maquiladora APA requests with the Mexican and US tax authorities. He has also been certified as a financial consultant from Mexico's Securities and Banking Commission. He holds a MSc degree in economics and finance from Warwick University's Business School (UK) and a BA in economics from Pan American University (Mexico City).

Simón Somohano

Deloitte Mexico

Río Lerma No. 232 Piso 9

C.P. 06500, Ciudad de Mexico

Mexico

Tel: + 52 (664) 622-7872

Email: ssomohano@deloittemx.com

Website: www.deloitte.com

Simón Somohano, Deloitte Mexico (Galaz, Yamazaki, Ruiz Urquiza, SC), is a tax partner based in Mexico City and Tijuana responsible for the transfer pricing practice in Latin America and the Caribbean region.

He has more than 26 years of experience in the application of tax, economic and financial criteria in transfer pricing, anti-dumping/subsidy investigations, valuation analysis of intangibles, double tax treating issues, planning, business model optimisation, structuring and economic consulting.

Under his leadership, Deloitte's regional transfer pricing practice has been consistently recognised as one of the leading practices in Latin America, including winning the 2016 award for Mexico Transfer Pricing Firm of the Year from International Tax Review.

He has consistently been named as one of the world's leading transfer pricing advisers by the prestigious Transfer Pricing Expert Guide published by Euromoney/Legal Media Group.

His clients include several Fortune 500 multinational companies doing business in Mexico. He has extensive experience and a successful track record leading the Mexican negotiations of advanced pricing agreements (APA); mutual agreement procedures (MAP) and transfer pricing examinations with Mexican and foreign authorities, teaming with colleagues in Deloitte's global transfer pricing network. In this venue, Simón led the technical and economic team that successfully obtained in 2016 a hallmark resolution on a transfer pricing dispute through the recently introduced alternative dispute resolution procedure: conclusive agreement.

Simón advises in a variety of industry sectors, mainly automotive, manufacturing and maquiladoras, retail and consumer goods, real estate, technology, and the energy and resources market.

He also provides specialised counselling to clients in several anti-dumping and subsidy investigations.

Simón is a frequent guest speaker in international business forums in Mexico and abroad.

He has authored various articles on transfer pricing in specialised journals and is a co-author of the Transfer Pricing International Handbook, A Country-by-Country Guide published by the International Tax Institute and Transfer Pricing, and A Theoretical, Legal and Practice Framework, published by the Institute of Chartered Accountants (Mexico).

His professional accreditations and affiliations include being a board member of the transfer pricing committee of the Institute of Chartered Accountants. In addition, as the lead transfer pricing adviser to the National Export Manufacturing and Maquiladora Council (INDEX), Simón has lead the technical negotiations for the establishment of a transfer pricing methodology applicable to about 700 Maquiladora APA requests with the Mexican and US tax authorities. He has also been certified as a financial consultant from Mexico's Securities and Banking Commission.

He holds a MSc degree in economics and finance from Warwick University's Business School (UK) and a BA in economics from Pan American University (Mexico City).

Hernaldo Vega
	Deloitte Mexico Rio Lerma 232, 9th Floor Col. Cuauhtémoc, 06500 Ciudad de México Mexico Tel: +52 (55) 5080 6258 Email: hevega@deloittemx.com Website: www.deloitte.com Hernaldo Vega, Deloitte Mexico, is the tax and legal partner and is actively engaged in assisting clients with tax audits, lobbying activities before the tax authorities and to selective litigation. He has achieved experience in domestic and international tax planning, tax controversy, and tax litigation. Hernaldo has 14 years of experience in regulatory and dispute areas of the Tax Administration Service of the Mexican Ministry of Finance, initiating as a technical supervisor and concluding as an assisting director in the large taxpayers' administration. He has specialised in tax controversy for more than nine years at Deloitte Mexico where he has attended a range of high-profile clients in relation to the tax authorities audit activity and formal taxation disputes. Hernaldo obtained his bachelor's degree in law in 1994 from the Autonomous University of Chihuahua, Mexico, and he also earned a bachelor's degree in accounting from the same university in 2005. He is an active member of the Mexican Bar, Lawyers College, and the College of Public Accountants of Mexico. More recently, he finished his master's degree in financial strategy at the Panamerican University in 2015. Hernaldo has taught at several universities including the Monterrey Institute of Technology and Higher Education (2014–15) on a postgraduate degree in taxes (Mexican tax regulatory frame) and the Escuela Bancaria y Comercial (2011–present) on tax law and the tax review process.

Hernaldo Vega

Deloitte Mexico

Rio Lerma 232, 9th Floor

Col. Cuauhtémoc, 06500

Ciudad de México

Mexico

Tel: +52 (55) 5080 6258

Email: hevega@deloittemx.com

Website: www.deloitte.com

Hernaldo Vega, Deloitte Mexico, is the tax and legal partner and is actively engaged in assisting clients with tax audits, lobbying activities before the tax authorities and to selective litigation. He has achieved experience in domestic and international tax planning, tax controversy, and tax litigation.

Hernaldo has 14 years of experience in regulatory and dispute areas of the Tax Administration Service of the Mexican Ministry of Finance, initiating as a technical supervisor and concluding as an assisting director in the large taxpayers' administration. He has specialised in tax controversy for more than nine years at Deloitte Mexico where he has attended a range of high-profile clients in relation to the tax authorities audit activity and formal taxation disputes.

Hernaldo obtained his bachelor's degree in law in 1994 from the Autonomous University of Chihuahua, Mexico, and he also earned a bachelor's degree in accounting from the same university in 2005. He is an active member of the Mexican Bar, Lawyers College, and the College of Public Accountants of Mexico. More recently, he finished his master's degree in financial strategy at the Panamerican University in 2015.

Hernaldo has taught at several universities including the Monterrey Institute of Technology and Higher Education (2014–15) on a postgraduate degree in taxes (Mexican tax regulatory frame) and the Escuela Bancaria y Comercial (2011–present) on tax law and the tax review process.

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