Mexico

PwC

Mariano Escobedo 573

11580 México, DF

Mexico

Tel: +5255 52636069

Email: fred.barrett@mx.pwc.com

Website: pwc.com/taxcontroversy

Fred Barrett is partner-in-charge of the transfer pricing practice of PricewaterhouseCoopers in Mexico.

Fred has more than 34 years of tax experience dealing with international tax and transfer pricing matters for large multinational corporations, individuals, partnerships, publicly traded and closely held business interests including reorganisation and acquisition assistance. He has extensive transfer pricing documentation experience in a variety of industries.

In recent years Fred has been specialising mainly in transfer pricing, particularly concerning strategy and technical transfer pricing matters in audits and disputes, APAs and MAPs, and restructuring assistance in value chain model changes. Presently actively involved in strategic risk assessments on TP matters, including BEPS issues and proactively helping clients to manage applicable risks. Fred's team is also keenly focused on producing the right documentation the first time.

Fred has been providing tax consulting on international transactions, including mergers and acquisitions, debt financing alternatives and corporate restructurings in several industries including financial services, mining, mutual funds, insurance, consumer products, pharmaceutical, telecommunications, manufacturing, automotive, retailing, real estate, construction, transportation, oil and gas and refining.

He has broad experience in FAS 109, FIN 48, Mexican consolidation rules and maquiladora tax issues. Fred also serves as a tax engagement partner for several multinational companies.

He is chair of the Tax Matters Commission at the American Chamber of Commerce of Mexico and is a former member of the International Tax Committee at the Mexico City School of Public Accountants. Fred is an associated member at Fomento Educacional, AC.

Fred is fluent in Spanish.

He has been a US CPA since 1982 and is now a CPA in Florida. He graduated from the University of Florida and has been a Mexican income tax adviser since 1993.

PwC

Mariano Escobedo 573

Col Rincón del Bosque

11570 México, DF

Mexico

Tel: + 52 55 52638571

Email: adolfo.calatayud@mx.pwc.com

Website: www.pwc.com.mx

Adolfo Calatayud is the leading partner of the tax controversy practice in Mexico. He has more than 16 years of professional experience in transfer pricing and international tax services for private and public companies.

He now holds the position of president of the Transfer Pricing Commission of the Mexican Institute of Public Accountants, and an active member of the International Tax Commission of the Mexican Board of Public Accountants.

In his role as tax controversy and dispute resolution (TCDR) lead partner, Adolfo has participated in several tax audits, bilateral and unilateral advance pricing agreements (APAs) and mutual agreement procedures (MAPs).

Before he became a partner in PwC, Adolfo was part of the Mexican Tax Administration Service, acting as director of audits to foreign residents, within the International Tax Division.

Adolfo has two postgraduate degrees in international taxes (from ITAM and Duke University), as well as an academic major in international taxes (from the Tax Studies Institute and the Ministry of Public Finance in Spain.

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 companies 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 the 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

Av Lazaro Cardenas 2321 Pte PB

Col Residencial San Agustín

Monterrey 66260

Mexico

Tel: +52 81 81337360 x7360

Email: gmanideita@deloittemx.com

Gonzalo Mani is a Deloitte Mexico 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 Universidad Autonoma de 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 has been a business tax partner at Deloitte Mexico 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, 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 representative for the Ministry of Finance before the US and Canadian Government for tax and customs affairs, in Washington, DC.

Mauricio earned his bachelor's law degree in 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) & political history (1998); Universidad Iberoamericana: tax law I (1998); Instituto Tecnológico Autónomo de México: Mexican taxation (1995).

PwC

Mariano Escobedo 573

Col. Rincón del Bosque

1170, México DF

Mexico

Tel: +52 (55) 52 63 61 24

Email: sergio.perez.cruz@mx.pwc.com

Website: pwc.com/taxcontroversy

Sergio Pérez is a transfer pricing partner at PwC's tax controversy and dispute resolution practice in Mexico. Before joining the firm, Sergio held a high level position at the Mexican SAT's Large Taxpayers Administration. Over his more than eight year career at SAT, besides leading a large transfer pricing audit team, he also was in charge of the APA programme in Mexico and conducted competent authority negotiations for bilateral APAs and mutual agreement procedures (MAPs) with other tax administrations. His areas of expertise include tax policy, cross-border transactions, operational restructures, transfer pricing, permanent establishment (PE) issues as well as settlement negotiations, audit management and tax conventions.

As Mexican delegate of OECD's Working Party 6, Sergio was involved in the Business Restructuring Project and also in the Comparability and Profit Methods Project which resulted in guidance that was included in the latest version of the OECD's Transfer Pricing Guidelines. He also collaborated in the Intangibles Project and was part of focus groups on specific subjects for the BEPS initiative. Within the framework of the OECD Global Forum on Transparency and Exchange of Information, Sergio was appointed by Mexico as an evaluator and reviewed OECD and non-OECD tax jurisdictions for the project.

Sergio is an active participant of the IFA México and now chairs the Transfer Pricing Committee and attends the BEPS Committee. As a collaborator at the OECD's education programme, Sergio has been invited to lecture to other tax administrations in Central America, South America and Asia and also at regional forums on international taxation organised by CIAT, GIZ, IMF and the World Bank, enhancing an effective exchange of experiences with colleagues and practitioners. Sergio is invited on a regular basis by academic and business associations to present his views on different taxation topics.

Sergio is an economist from the Instituto Tecnológico Autónomo de México (ITAM) one of the world's leading economics schools, where he received an academic excellence award, but he also studied physics with emphasis in nuclear sciences at Mexico's National University. His strong mathematical and analytical skills and his international experience contribute to his ability to develop innovative solutions in restructuring, transfer pricing, international taxation and competent authority negotiations.

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: 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, pharmaceutical, automotive, telecommunications, 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 occupied for 17 years different relevant positions at the Ministry of Finance and the Tax Administration Service. 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, 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 for 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.