Mexico

PT de La República 3304, Piso 1

Ciudad Juárez, Chihuahua

México, 32330

Mexico

Tel: +52 656 629 1346

Fax: +52 656 629 1399

Email: luis.carbajo-martinez@bakermckenzie.com

Website: www.bakermckenzie.com

Luis Carbajo has extensive experience in the areas of international tax planning, M&A, permanent establishment (PE), cross-border transactions, inter-company pricing, taxation of non-resident entities and individuals, corporate taxes and other taxes such as VAT, flat tax, and in planning and litigation, on social security contributions and other local and municipal taxes.

Luis has been the lead counsel on tax audits and tax litigation concerning complex subjects, including:

• Litigation related to the tax treatment for multi-million dollar incentives received by companies for R&D centres located in northern and central Mexico, securing favourable court rulings;

• Challenges of multi-million dollar tax assessments issued against pharmaceutical companies for disallowed deductions, securing favourable resolutions;

• Handling of complex tax litigation related to the tax treatment of charter payments to non-residents without a PE in Mexico, securing favourable court rulings;

• Handling of tax litigation regarding royalty payments to software developers;

• Tax litigation related to transfer reports challenged by the tax authority, securing favourable verdicts acknowledging the present reports as well as rulings ordering the adjustment of the transfer pricing reports;

• Handling of complex tax audits with observations concerning royalty payments, exchange losses and gains, and technical assistance services;

• Successful handling of tax audits related to the application of maquiladora tax incentives; and

• Assisted international companies on the tax treatment for charter hire payments to non-resident companies, securing favourable resolutions.

Luis received a law degree from the Universidad de Guanajuato, Mexico; a certificate on special studies of administration and management from Harvard University in 1994 and a joint honours degree in international tax from Harvard Law School in 1995. He also completed a transfer pricing specialisation jointly offered by the Universidad Anahuac and the Spanish Universidad de Cantabria.

Blvd Manuel Avila Camacho, Piso 12

México DF

México, 11009

México

Tel: +52 55 53514148

Fax: +52 55 5351 4148

Email: ulises.castilla@bakermckenzie.com

Website: www.bakermckenzie.com

Ulises Castilla has more than 20 years of experience advising on tax strategies for the business sector and acting as a litigator in the private and public sectors. He has a deep understanding of tax issues related to financial institutions as well as company consolidation for tax purposes.

Before joining the firm, he was the central litigation administrator of large taxpayers for the Tax Administration Service (SAT), a decentralised body of the Mexican Secretariat of Finance and Public Credit.

He is an accomplished keynote speaker on tax matters, having spoken at various seminars organised by the Mexican Bar Association, the University of California, San Diego, Mexico's Accounting Institute, EuroSocial, the IFA Commission, and other prominent associations and universities.

Ulises has acted as counsel on tax audits and tax litigation on complex subjects, including:

• Adding or divestiture of companies in the tax consolidation regime;

• Mexican taxation on oil rigs and its impact on tax payments;

• Tax effects of varying shares of consolidated companies;

• Refusing deduction of expenses for advertising to pay royalties for using a brand; and

• Financial matters including:

a) Mechanical calculation and deductibility of global preventive reserves;

b) Tax effects relating to income tax from the sale of nonperforming loans;

c) VAT treatment on the purchase of securities and repurchase;

d) Treatment of mortgage commissions;

e) Effect on income tax resulting from the determination of the annual adjustment for

inflation; and

f) Deductibility of additional reserves.

Ulises received a law degree from the Universidad Tecnologica de Mexico, undertook post graduate studies in constitutional law at the Universidad Panamericana in 1999, and a master's degree in international business of Universidad Tecnologica de Mexico in 2003.

Paseo de la Reforma 505

Col Cuauhtémoc

06500 México, DF

México

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 is a Deloitte Mexico partner, leader of the Deloitte Mexico tax and legal practice and 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 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 the 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). His 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 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.

Galaz, Yamazaki, Ruiz Urquiza, SC

Paseo de la Reforma 489, piso 6

Colonia Cuauhtémoc, 06500

México, DF

México

Tel: +52 55 5080 6969

Fax: +52 55 5080 6001

Email: jizaza@deloittemx.com

Website: www.deloittemx.com

Juan Carlos Izaza is a partner of Deloitte Mexico, based in Mexico City. Juan Carlos has more than 35 years of experience in tax, including advising on and development of national and international acquisitions, mergers, cross-border transactions and the implementation of different tax planning structures.

Juan Carlos has extensive experience in administrative and tax litigation. He is a regular speaker at internal seminars and is an active member of the Mexican Bar Association (BMA), International Fiscal Association (IFA), Fiscal Studies Academy of Public Accounting (AEFCP), National Association of Corporate Counsels (ANADE) and the National Association of Tax Experts (ANEFAC).

Juan Carlos has been recognised by several professional guides including the Guide to the World's Leading Tax Advisers, Chambers & Partners and Best Lawyers as one of the leading Mexican tax lawyers.

Juan Carlos earned a law degree from the Universidad Nacional Autónoma de México.

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 national leader for tax litigation. He has been with Deloitte for 15 years. His principal areas of expertise are tax litigation, tax advisory and consultancy.

Gonzalo 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.

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 pursuing a master´s degree in business 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.

Paseo de la Reforma 489, P 6 Col Cuauhtémoc

Mexico, DF

Mexico

Tel: +52-55-50806960 x6960

Email: rmontano@deloittemx.com

Reginaldo Montano Rodriguez is a Deloitte Mexico partner and attorney-at-law with 20 years of experience of both private and public tax matters. He has served as a tax consultant for domestic and foreign organisations. His specialisms include tax planning and litigation, tax treaties, income tax, flat business tax, VAT and excise tax.

Reginaldo has served as director of the Legal Department/Tax Policy Division and director of the Rulings Department of the Mexican Ministry of Finance/International Tax Department. He has also represented the ministry before the OECD.

Reginaldo serves as the coordinator of the Case Law and Legislation Committee of the International Fiscal Association (IFA), and as sub-coordinator of the Tax Law Commission of the Mexican Bar Association (BMA). He has participated as a speaker in numerous forums.

Mariano Escobedo No 573

Col Rincón del Bosque

CP 11580 México, DF

México

Tel: +52 (55) 52-63-57-34

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

Website: pwc.com/taxcontroversy

Karina Pérez is part of PwC's global tax controversy and dispute resolution (TCDR) team and is the leading TCDR partner for Mexico and Latin America.

In this capacity, she has been engaged in important projects that have successfully resolved international disputes in different industries, such as consumer products, pharmaceutical, automotive, telecommunications, and oil and gas.

Karina joined PwC in 2008 and has practised in the area of international taxation for more than 21 years.

Before joining PwC, she worked at the Mexican Treasury Department and Tax Administration Service (TAS) for 17 years.

In these roles, she negotiated 43 of the Mexican tax treaties with the major commercial partners of Mexico, including the US-Mexico tax treaty and its protocol; she worked on proposed tax legislation and regulations, issued private rulings for international transactions and was the competent authority in several mutual agreement procedures for treaty interpretation and application.

During this time, Karina issued technical and operational guidelines applicable to central and field officers of the legal, audit and collection divisions of the large taxpayer unit of the TAS.

As a tax official, she served as a delegate for Mexico at the OECD in different working groups, such as Working Group No. 1 on treaties and related issues and the Committee of Fiscal Affairs.

Karina has been a member of the IFA's Mexican branch for several years and has a leading role at the Case Law Committee of this association where advisers, tax officials and tax judges discuss international controversies on a regular basis.

She was recently appointed by the International Bureau of Fiscal Documentation as the country expert for Mexico in the global tax treaty commentary project where she will provide expertise based on her recognised knowledge of Mexico's treaty practices.

Karina also has published numerous articles for publications such as International Tax Review. She graduated as a lawyer from the Escuela Libre de Derecho.

PT de La República 3304, Piso 1

Ciudad Juárez, Chihuahua

México, 32330

Mexico

Tel: +52 656 629 1380

Email: juan.valles-zavala@bakermckenzie.com

Website: www.bakermckenzie.com

Juan Carlos Valles is an adviser of multinational companies with experience in the areas of international tax planning, permanent establishment issues, cross-border transactions, taxation of non-resident entities and individuals, corporate taxes, and also on indirect taxes such as VAT. He also handles tax litigation, customs and foreign trade matters.

Juan has a strong background in foreign trade and customs matters, and has advised companies on international trade and customs regulations such as tariff classification, customs valuation, rules of origin, non-tariff regulations and restrictions (including import permits, quotas, Mexican official standards and anti-dumping practices), Mexico's network of free trade agreements, export promotion programmes (such as PROSEC and maquiladora), and audits.

Juan has experience representing taxpayers in the following matters:

• Representing companies from the automotive, electronics, pharmaceutical, major appliances, distribution, and apparel industries on tax and customs planning;

• Handling of tax and customs audits before tax and customs authorities;

• Handling of litigation matters to nullify tax assessments; and

• Planning on use of Mexico's tax and trade agreements.

Columbia Law School (LL.M.) (2005)

Instituto Tecnologico y de Estudios Superiores de Monterrey (Ll.M "Maestra en Derecho Commercial International") (1999)

Instituto Tecnologico y de Estudios Superiores de Monterrey (Lic. en Derecho) (1997)

He is a member of The National Association of Corporate Lawyers and The Mexican Institute of Financial Executives.