AMAZON

We provided advice on the definition of the most tax efficient structure for the sale of goods through their platform in Colombia and their retail operations by way of local stores in the country. The complexity associated with this advisory stem from the existence of different business models and payment structures that implied different treatments and formal obligations. Having local and international retail sales both in physical stores and through the platform, in different jurisdictions, require deep analysis on legal, regulatory, tax, exchange, and customs terms.

BHP BILLITON

We advised BHP on the compliance requirements derived from the sale of its 33.3% participation in Carbones del Cerrejon, the world’s largest open sky coal mine, to Glencore. The preparation of the relevant tax returns involved a detailed analysis of the tax basis available and the preparation of a supporting file in case of a tax audit on the matter.  All this is of paramount importance for BHP, considering its position in Colombia and its international coal business operation

INTERCONEXIÓN ELÉCTRICA COLOMBIA PANAMÁ

We led the analysis of the restructuring of the electric interconnection project that intends to link South and Central America’s energy markets. This project is of paramount importance for the export of energy from Colombia to Panama and other countries in Central America. The project is interesting as it involves the difficulties associated to changing prices of the energy market and the tax and regulatory challenges of the sale of energy among different jurisdictions.

NORTHLAND POWER

GREENLAND INVESTMENTS

Greenland is one of the top fruit exporters of the country. We provided advisory on the internationalization of its business operation both in Europe and in North America. The advisory implied the definition of corporate vehicles to channelize the investment and the definition of a holding structure and strategy intended to make applicable the provisions of tax treaties and international investments agreements entered into by Colombia. The complexity of this advisory stem from the fact that it involved the reorganization of different operative entities in different jurisdictions and the existence of other shareholders.