Meet the team

Tax and International Trade

Philippi Prietocarrizosa Ferrero DU & Uría

Bogota, Colombia
+1 other location
  • Barranquilla, Colombia
+57 601 3268600
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Deals

Santa Ana Florestal: Counsel to Santa Ana Florestal in order to obtain exempt income for a carbon credits generation project.

Cogent Communications Colombia: Counsel in the strategy to import goods into Colombian territory from other jurisdiction in which the client has local presence. In particular, we reviewed the Free Trade Agreements signed by the Colombian government to deeper understand the tax and custom benefits that the client may enjoy in accordance with the client’s needs and nature of its operation.

Daabon: Counsel in providing legal comments with respect to bills regulating the palm oil industry proposed by other entities and government agencies. We carried out a profound analyses of the current status of the Colombian provisions with respect to imports of palm oil. As well as, provided comments and proposed amendments to reinforce its development.

Sonova: Counsel in the internal procedures, policies and practices of the Colombian Customs Authority to unseized the client´s merchandise. We reviewed the filings made by the client, specifically, the import declaration and import registration of goods in order to release the merchandise, as well as the client´s compliance on the import duties.

Acepalma: Counsel in its day-to-day operation to import goods into Colombian territory from free trade zones to stimulate its economic growth, development and share in the Colombian market.

Under Armour: Counsel in the internal procedures, policies and practices of the Colombian Customs Authority to release the client´s merchandise into the national territory.

Banasan: Counsel in the design and implementation of a tax and corporate structure for this leading player of the banana market. This structure was challenging because Banasan develops different stages of the banana production, such as planting, transportation, distribution and marketing, through separate entities in several jurisdictions.

Corporación Soluciones Energéticas Integrales S.A. Cosenit S.A: Counsel in the tax benefits from the income tax, VAT and custom duties stance for the client, as a taxpayers generating energy for sale or self-consumption from renewable energy sources. This was particularly challenging because we devise a comprehensive solar power plant lease agreement to benefit the Client. Furthermore, we review and carried out a profound analysis of the tax and accounting regulations applicable to such agreement.

Teleperformance: Counsel in a litigation case concerning the reimbursement of income taxes. We obtained a favourable decision issued by the Council of State (highest Tax Court in Colombia).

Conexred: Counsel in the design of a stock option plan for Conexred and its employees. Pursuant Colombian provisions, stock option plans require a detailed analysis of tax, labor, corporate and regulatory implications.

Organigram

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Team Services

Our tax team understands how the businesses of our clients work to help them achieve their objectives, by means of the design of local and cross-border structures the principal focus of which is the solid and efficient management of taxes, through the following areas:

Local and off-shore tax planning:

  • Structuring of cross-border transactions, including the acquisition of domestic corporations, companies and/or assets by foreign companies.
  • Representation of national and international clients in the acquisition of domestic and foreign entities and businesses.
  • Legal assistance in the structuring of cross-border “joint ventures”.
  • Corporate, individual and independent workers tax planning, addressed to optimizing the income tax, VAT or any applicable tax.

International reorganizations:

  • Tax structuring of cross-border operations such as mergers, spin-offs, liquidations, and in general, reorganizations.
  • Based on local or foreign applicable laws, advisory on optimizing such cross-border reorganizations.
  • Advice on the tax effects derived from investment and financing instruments.
  • We have the resources our customers need to design their corporate structures, drafting contracts and offering the required strategies to business group structures, in order to achieve an optimal tax burden.

Transfer pricing:

  • Preparation of economic analysis of operations with their economic related parties.
  • Preparation of transfer pricing analysis of operations with their economic associates.
  • Structuring of transnational operations, taking into account functions, risk, assets and flow of resources.

Private clients reorganizations and tax planning:

  • We work jointly with the Private Clients practice of the firm, in order to render services of family net worth and tax planning.
  • Long term net worth and tax planning, even for future family generations, to families owning assets abroad, which members could be Chilean, Colombian, Peruvian or non-residents.
  • Reorganizations of assets through holding companies, among other mechanisms.Tax litigations and tax proceedings:
  • Analysis of potential tax contingencies and tax due diligences.
  • Tax litigations before the tax authorities and Courts.
  • Filing and assistance in the request for Rulings to be issued by the tax authorities (Rulings and particular instructions).

Customs and international trade:

  • Structuring of domestic and international operations and transactions which involve matters related to foreign trade, customs and foreign exchange.
  • Advisory services in the structuring of legal customs alternatives that allow optimization of foreign trade operations (Special Import-Export Services, the so-called Plan Vallejo, Free Trade Zones and Trading Companies).
  • Import and export audits in order to (i) detect relevant contingencies; (ii) design alternatives to mitigate such contingencies and (iii) propose a company’s procedure to ensuring compliance with all customs laws.
  • Advisory services and representation of domestic and foreign companies in administrative and litigation proceedings involving foreign trade, customs and foreign exchange.

Testimonials

“The law firm has at its disposal all the areas of law that I need as a client; this is a great advantage as it has all the resources required to provide comprehensive tax advice that takes into account almost all of the possible implications. It also has excellent contacts with the relevant authorities”. 

“The team is always cohesive and in tune with the client’s needs. The team is very well integrated and comprised of lawyers with different skills”.

“Martín Acero and his tax team are clear in their assessments. Lawyers are practical in presenting solutions when things look difficult; they are orderly and fulfil the commitments acquired in the delivery of the advice”. 

“In general, the partners of the firm are people who have high national recognition, therefore they are very well informed”.