Mexico

PwC

Mariano Escobedo No. 573

Col. Rincón del Bosque

CP 11680, Mexico DF

Mexico

Tel: +52 (55) 52 63 57 34

Email: karina.perez.delgadillo@mx.pwc.com

Website: www.pwc.com/taxcontroversy

Karina Pérez is part of the transfer pricing and tax controversy and dispute resolution team in Mexico. Karina has experience in successfully solving complex international tax controversies in different industries such as the financial services, consumer products, pharmaceuticals, automotive, telecommunications, and oil and gas sectors. She is a partner that has practised in the area of international taxation for more than 25 years and has recognised experience in Competent Authority processes, managing audits and settling disputes. She maintains close contact with competent authorities around the world.

Before joining PwC she worked at the Central Bank, and at the Ministry of Finance and the Tax Administration Service for 17 years in different relevant positions. Under these responsibilities she negotiated 44 of the Mexican tax treaties, including the treaties and protocols with the US, Germany, UK, Netherlands, Switzerland, Spain, Canada, Ireland, Singapore, Brazil, India, and Chile. She also negotiated exchange of information agreements with the US and Canada. Karina worked on proposed tax legislation and regulations regarding international transactions, issued international private rulings and was the Competent Authority for mutual agreement procedures with different jurisdictions. She was responsible for the registry of foreign financial institutions, including pension and investment funds and was in charge of administrating reporting obligations regarding the placement of securities abroad. As part of her responsibilities as the legal counsel of the large taxpayers unit she issued internal guidelines applicable to central and field officers for the legal, audit and collection offices. As a tax official she was the delegate for Mexico at the OECD in different working groups (including the committee on fiscal affairs, working group 1, treaties and related issues).

Karina has been, for several years, a member of the IFA Mexican branch and participates actively at the case law committee of this association where advisers, tax officials and tax judges discuss international controversies on a regular basis.

She has participated in different publications where she provides her expertise based on her recognised knowledge of Mexico's tax treaties.

She graduated as a lawyer from the Escuela Libre de Derecho.

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 Deloitte Mexico 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.

Deloitte Mexico

Paseo de la Reforma 505

Floor 23

Mexico

Tel: +52 (55) 5080 6600

Fax: +52 (55) 5080 6001

Email: jorjimenez@deloittemx.com

Website: www.deloitte.com

Jorge Jiménez Cañizares, Deloitte Mexico, has been a lawyer and tax adviser of the financial sector since 1989. In the course of his professional career he has specialised in consulting in general corporate taxation, VAT (national and international operations), international taxation, double taxation treaty application, and customs law. He leads the firm's practice dedicated to the tax consulting and defence services for financial and insurance institutions, as well as regulatory aspects of the same. Additional practice areas include assistance regarding audits by tax authorities, general tax litigation and amparo litigation. He is a Deloitte Mexico partner of the tax and legal practice and was named insurance sector leader of the financial services industry.

Jorge is an active member of the Mexican Bar Association and the Academy of Tax Studies of the Public Accounting Profession. Chambers & Partners legal publishers included Jorge in the list of Chambers Latin America's leading lawyers for business, as a lawyer with a superb reputation for tax work with insurance companies and financial institutions.

Deloitte Mexico

Paseo de la Reforma 505

Cuauhtémoc

C.P. 06500 Ciudad de México

Mexico

Tel: +52 (55) 5080-6660

Email: cakoller@deloittemx.com

Website: www.deloitte.com

Carl E Koller Lucio, Deloitte Mexico, joined in February 2014 as a partner in the international tax area of the firm's tax practice, after 14 years' practice as a partner in a leading Mexico City boutique tax law firm. He has accumulated close to 20 years of practice in the tax field and 26 years of overall legal practice.

Although Carl's practice was previously focused on tax controversy and tax litigation, he now balances a combination of corporate and international tax consulting and planning with a selection of controversy and litigation cases. It draws on his knowledge in tax and civil, commercial and corporate law to provide, as circumstances may dictate, detail-driven, high-quality risk mitigation advice, or for the design and implementation of required defensive strategies. A further and principal day-to-day commitment of his tax practice, particularly for European and North American inbound investment, is to generate a clear understanding of the relevant legal-tax issues and potential scenarios and solutions affecting clients. In tax controversy and litigation, Carl's necessary un-delegable and personal involvement in each case is a key commitment, particularly in a more recent, highly adversarial controversy environment.

Carl has been lead litigation partner in cases deriving in the relevant jurisdictional precedent, including initial and favourable Supreme Court sentences. In addition, through the Mexican Bar Association, he has participated in a number of successful lobbying efforts to counter government initiatives at the constitutional and legal levels that would have significantly curtailed taxpayers' rights. Carl is also knowledgeable in aspects of international law, having participated as counsel to arbiters in two NAFTA investment protection arbitrations, in which the main issues centred on a taxation background. He has participated with local counsel in tax controversy matters in certain Latin American countries.

Carl received his law degree from ITAM in 1994 (cum laude) and his Master of Laws from Duke University School of Law in 1995 (his master thesis was published in the subject matter relevant journal, Duke Environmental Law and Policy Forum). He passed the New York State Bar exam in 1995. More recently, in 2011-2012, Carl took a sabbatical and obtained a full-time MBA degree (cum laude) from the leading Mannheim Business School in Germany, for which he was one of two recipients of the Wilhelm Müller Stiftung (Foundation) Award in August 2013.

Regarding professional associations, he is an active member of the Mexican Bar, Attorney's College and the Tax Studies Academy for Public Accounting (sponsored by the Mexican Institute of Public Accounting), and periodically publishes and lectures on relevant tax issues.

He has received peer and client acknowledgment in specialised international publications as a leading tax attorney in Mexico since 2008.

He is a native English and Spanish speaker.

EY Mexico

Av. Ejército Nacional 843-B

Torre A, Piso 5

Del. Miguel Hidalgo, 11520

Mexico City

Mexico

Tel: +52 55 5283 1439

Email: jorge.libreros@mx.ey.com

Website: www.ey.com

Jorge Libreros is the leading partner of the tax controversy practice at EY Mexico.

Jorge is a law graduate from Escuela Libre de Derecho in Mexico City and has more than 20 years' experience in controversy and international taxation matters. He has been professor of several tax courses at Escuela Libre de Derecho. He is often invited to speak at local and international tax forums.

Before joining EY, Jorge worked for more than 10 years at the Mexico Tax Administration Service where he held various offices, including the international tax legal affairs department and the international audits department. He was Mexico's delegate for several OECD working groups and the Inter American Center of Tax Administrations.

Jorge's experience at the Tax Administration Service compromised of local legislation and tax treaty interpretation, exchange of information in tax matters, customs, rulings, free trade agreements, origin verification, legal proceedings, and international transactions.

Jorge specialises in tax law and international taxation focusing on controversy matters. He is also highly qualified in national and international consulting, income tax, VAT, foreign trade, import duties, origin verification and the North American Free Trade Agreement (NAFTA).

Deloitte Mexico

Av Lazaro Cardenas 2321 Pte PB

Col Residencial San Agustín

Monterrey 66260

Mexico

Tel: +52 81 81337360 (x7360)

Email: gmanideita@deloittemx.com

Website: www.deloitte.com

Gonzalo Mani, Deloitte Mexico, is a partner and the national leader for tax litigation. He has been with Deloitte for 15 years. His principal area of expertise is tax litigation. He has 20 years of experience in trial law related to complex tax matters. He has helped clients challenge tax laws which have set national judicial precedents.

Gonzalo has been a professor at Iberoamericana University, La Salle, and Anahuac del Sur. He has also taught degree programmes at the Bank and Commercial School in Mexico City and in the Public Accountants School of the Public Accountants Institute in Nuevo León, Mexico.

Gonzalo has written several essays on tax topics, the vast majority of which have been published in leading Mexican tax publications. He has advised writers of the business section of the newspaper El Norte, one of the most prestigious newspapers in Mexico. He is a constant speaker in the most important tax lectures organised by universities and professional organisations.

Gonzalo studied law at the Anahuac University in Mexico City. He later graduated with a master's degree in tax law from Panamericana University. He later completed another qualification in tax law at the Anahuac University and in Civil Law at the Escuela Libre de Derecho. Gonzalo also earned a degree in common law from the National Autonomous University of Mexico in Mexico City. Gonzalo is now pursuing a master's degree in business and corporate law at the University of Monterrey (UDEM).

Gonzalo is a member of the Mexican Lawyers Bar Association and the National Tax Specialists Association (ANEFAC) Chapter Monterrey.

Deloitte Mexico

Paseo de la Reforma 489, P 6 Col.

Mexico City

Mexico

Tel: +52 55 50807040

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 served for nine years in the Ministry of Finance. Before joining Deloitte, he worked 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 1999–2001 he was a partner at Baker & McKenzie in Monterrey. From 1995–1997 he served as a representative for the Ministry of Finance before the US and Canadian governments for tax and customs affairs, in Washington, DC.

Mauricio earned his bachelor's degree in law 1993 from the Instituto Tecnológico Autónomo de México (ITAM). He holds a postgraduate degree from Harvard-ITAM (international taxation programme).

Mauricio has taught at several universities including the Instituto Tecnológico de Estudios Superiores de Monterrey (2010–present): postgraduate degree in taxes–litigation and defence processes; Universidad Anáhuac del Norte: tax law II (January–June 1999) and political history (1998); Universidad Iberoamericana: tax law I (1998); Instituto Tecnológico Autónomo de México: Mexican taxation (1995).

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 eight years. His principal area of expertise is tax litigation. He has 18 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.

Hugo has been a speaker at many conferences regarding tax matters, including the 8th 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 8th semester was taken at the University of North Carolina at Chapel Hill, US). He was later certified by the Judicial Law School with a degree in constitutional matters. He graduated with a master's degree in tax law from the Panamericana University and later completed another qualification from Sheltons SITTI in international taxation principles and planning. Finally, he obtained a degree in financial administration from the Panamericana 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.

EY

Av. Ejército Nacional 843-B, Torre A, Piso 5,

Del. Miguel Hidalgo, 11520, Mexico City

Mexico

Tel: +52 55 1101 6437

Email: manuel.solano@ey.com

Website: www.ey.com

Manuel Solano is the partner in charge of the international tax services group in Latin America for EY, as well as the managing partner of EY's tax practice in the Mexico and Central American region.

Manuel has more than 20 years' experience working in Mexico and Latin America on planning, acquisitions and controversy matters. He has a BS from Youngstown State University and a JD from Georgetown University Law Center. He also studied finance and economics at the Autonomous University of Central America.

As a member of the American Bar Association and the New York State Bar, Manuel has extensive experience in international tax consulting and planning matters. His experience encompasses advising multinational enterprises on the tax and legal implications of cross-border acquisitions and the establishment of foreign operations in Latin America, as well as controversy matters.

Over the years, Manuel has also been involved on assisting multinational clients on the defense of some of the larger supply chain, debt restructuring, IP migrations and transfer pricing related tax assessments in Mexico and other countries in Latin America.

He has co-authored both the 'Tax Management Portfolio Doing Business in Venezuela' and 'Tax Management Portfolio Doing Business in Mexico', as well as the 'Tax Management Portfolio on Transfer Pricing'. Manuel is a regular contributor of tax articles to Tax Notes International, Bloomberg BNA and the Journal of International Taxation.

Deloitte Mexico

Río Lerma No. 232 Piso 9C.P. 06500

Ciudad de Mexico

Mexico

Tel: +52 (664) 622-7872

Email: ssomohano@deloittemx.com

Website: www.deloitte.com

Simón Somohano, Deloitte Mexico, is a tax partner based in Mexico City and Tijuana responsible for Deloitte's transfer pricing practice in Latin America and the Caribbean Region.

He has more than 25 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 2016 Mexico transfer pricing firm of the year by International Tax Review.

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

His clients include several Fortune 500 multinational enterprises 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 at international business forums in Mexico and abroad. He has written 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, 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.

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 a tax director 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 bachelors 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 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.