The Baker McKenzie litigation practice in transfer pricing is one of the most recognised in Argentina, and represents some of the largest exporters in the grain industry, with a list of clients that include Archer Daniels Midland, and Alfred C Toepfer among others.
The firm’s extensive experience in the tax controversy and transfer pricing world is exhibited in its representation of Archer-Daniels-Midland Company (ADM). In April 2017, the Chamber of Appeals served notice to ADM of a ruling that confirmed the revocation of its 2005 tax assessment and confirmed ADM’s tax position in regards to the export transactions carried out during the tax period in 2005. Baker McKenzie advised ADM on filing an appeal with the Federal Tax Court against the 2005 tax assessment.
The team just recently welcomed Julieta Bellacomo as an associate in Argentina.
BaseFirma’s specialised transfer pricing practice focuses on its deep understanding of transfer pricing regulations, audit defence and local and regional taxes. Sandra Diaz leads the team in Argentina.
The firm’s transfer pricing specialists have provided analysis in order to coordinate and implement a documentation project in eight countries (Chile, Argentina, Ecuador, Colombia, Uruguay, Peru, Venezuela and Bolivia). Furthermore, it has designed and implemented the first cost contribution arrangement under BEPS guidelines. It accomplished this by developing an innovative model using administrator companies in Argentina and Uruguay for netting payments and charges among the client’s Latin American subsidiaries.
The firm’s extensive experience with transfer pricing matters in Latin America is further exhibited in its representation of Terumo BCT in devising and implementing an effective transfer pricing strategy.
Bruchou Fernández Madero & Lombardi, part of the Taxand network, is a full-service firm that provides comprehensive advice in relation to transfer pricing matters. It handles cases for a number of prominent clients such as American Express, Deutsche Bank and IBM. It also provides daily tax advice to clients including the Global Tax Network, Endesa and SITA.
The firm’s tax, customs, and foreign trade department is led by Matias Olivero Vila, who has more than 24 years of industry experience. Vila’s reputation among industry leaders has also earned him a number of distinctions for his work. Similarly, partner Ezequiel Lipovetsky and senior associate Juan Pablo have been credited with distinctions for their work in the area of transfer pricing.
Deloitte & Co's transfer pricing team consists of two partners and 26 other professionals. The practice is led by Horacio Dinice.
Estudio O’Farrell is a full service tax and transfer pricing firm. Its professionals are broadly experienced in providing advice to industries such as pharmaceutical, telecommunications and shipping. The transfer pricing practice is led by Miguel Teson, who is experienced in complex tax litigation, while the rest of the team is made up of four partners and four other fee earners.
The team of lawyers and in-house accountants assist clients in audits and with proceedings at all levels of the judicial process. It has interpreted transfer pricing rules and cases relating to the OECD’s BEPS guidelines in light of their legal precedence in Argentina.
Beginning in 2006 as a specialised tax and transfer-pricing firm, Grupo GNP has risen to be known as one of the foremost firms when it comes to matters of international tax, tax strategy, conservation, litigation, planning, controversy and transfer pricing services. It has extensive experience in the oil and gas, construction, investments and airline industries.
The firm’s experience in dealing with high-level transfer pricing transactions is exhibited in its representation of XL RE Latin America, where the team provided advice on restructuring its local business into a regional business as it began to provide more services across Latin America. The company’s new business model was defined in accordance with transfer pricing advice and business requirements.
The team welcomed Ignacio Garbers, Federico Garrone and Julian Aparicio as senior associates this year.
The transfer pricing team at Laiún Fernández Sabella & Smudt is made up of two partners: Fernanda Laiun and Tomas Smudt. The duo both work on the compliance and disputes aspects of transfer pricing. Laiun has been dealing with transfer pricing since 1999, when transfer pricing regulations were first introduced in Argentina.
Over the last year, the team supported an advertising company in designing transfer pricing reform-friendly cost sharing policies arising from software development outsourced to a main software developer. The case highlighted the firm’s strength as an integrated multidisciplinary team of accountants, economists and actuaries capable of creating a matrix to define and distribute costs along user subsidiaries, with a preventative control of income tax consequences in the context of the global transfer pricing report of the local company.
The firm also has an academic approach and participates in lectures and courses for tax-specialised chambers such as the Argentine Association of Fiscal Studies, as well as publishing papers on transfer pricing developments and disputes in national courts.
The firm recently added Eduardo Gomez and Natalia Wojtasik as tax analysts.
Rosso Alba Francia & Asociados is a prominent transfer pricing and tax controversy firm in Argentina, and currently has the largest market share in terms of transfer pricing controversies. It is headed by Cristian Rosso Alba, and the rest of the team includes in-house economist Matias Lozano and accountants Martin Grana and Juan Carlos Garcia, in addition to a team of specialist tax lawyers.
Over the past year, the transfer pricing team has won two major cases setting standards in the transfer pricing matters of commodity exporters, ruled unconstitutional decree 916/04 before the Federal Court of Appeals, and obtained a favourable ruling from the Attorney General in a leading debt-to-equity recharacterisation case.
The firm recently added Lorena Luipinacci as an accountant, and Patricio Sanchez Benitez and Natalia Micaela Lopresti as associate lawyers in the tax controversy and transfer pricing department.