Dentons Jiménez de Aréchaga

Tax

Martin Montoro is a Senior Associate in the Montevideo office. His practice is focused on Tax Law as well as International Trade, WTO and Customs.

Martin’s practice in Tax Law is based mainly on corporate taxation, business structures, tax planning and international taxation - particularly, within the frame of investments projects and cross-border transactions. He is a member of the Dentons’ Global Tax Group and regularly supports other offices at Dentons on tax issues for multinational companies operating in the region and/or planning to expand into Uruguay. Martin also participates in tax litigation and dispute resolutions, representing several companies in tax inquiries and changes of tax rules.

Martin also engages the practice of International Trade, WTO and Customs, advising national and multinational companies not only with respect of taxes, duties, fees and other liens imposed at the customs clearance, but also counselling on trade barriers and trade compliance issues arising from customs operations. He is advisor, representative and spokesperson for the Importers and Wholesalers Association, a business chamber within the Uruguayan National Chamber of Commerce and Services that gathers the main food importers in Uruguay.

Martín has a deep knowledge in the Life Sciences and Healthcare industry, particularly with reference to sanitary regulations over consumption products. More recently, he is growing and broadening his proficiency in this industry throughout a permanent counselling on regulatory matters rendered for multinational companies from the cannabis, healthcare, and pharmaceutical sector.

Experience Experience Confidential: Advised a renowned technology company regarding taxes, customs duties, fees, and other charges that levy on international trade in goods transactions within and out the Uruguayan Free Zone. The assistance included a legal report addressing several tax and customs matters, explaining tax impact on foreign trade operations (import-transit-exports) and exemption or other benefits that could be applied by performing operations through a Free Zone regime. Importers and Wholesalers Association: Assisting this Association with reference to customs duties applied on certain food products from Argentinean origin due to protectionist measure carried out in Argentina (drawdowns over exports / promoted zones), counselling on the validity of this countervailing measure at the light of the WTO Agreement on Subsidies and Countervailing Measures. CaixaBank / Leading Spanish Bank: Advising the lenders on tax impact arising from a refinancing scheme for the Cerro Grande Windfarm in Uruguay, including the review of amendments proposed to the Facilities Agreement as well as the analysis of potential loss of withholding exemptions under the proposed modifications of the financial structure, due to the provisions of the double tax treaty between Spain and Uruguay. Confidential: Counseling on a project in connection with the EU - MERCOSUR Association Agreement. By this way, among several topics, we advised on the tax and trade compliance issues that Uruguay should amend to comply with the obligations arising from the Association Agreement, mainly tax, customs duties and charges reductions/exemptions in connection with international trade. Global Consumer goods company: Advising a Free Zone user regarding the tax impact in Uruguay arising from amendments to the Free Zone regime in connection with the tax exemptions related to the use/acquisition of intangible assets (accordingly with BEPS Action 5). The counsel envisaged the review of several agreements between said company and other affiliates related to the acquisition/transfer/use of intangibles assets in order to mitigate issues related to the tax exemptions. Copasa: Advising on the business structure and tax planning to carry out the construction of the 186-mile highway highway and its operation and maintenance for a 20-year term. The advice included the taxability and liability of income arising from the work activity of several non-resident employees contracted abroad that will perform their service in Uruguayan territory under a temporary transfer regime.

Spanish and English

Member, Uruguayan Tax Study Institute