Colombia



World TP Reviews

Transfer pricing
Baker McKenzie

A prominent firm in the Colombia market, Baker McKenzie’s tax services span a range of areas, including tax planning, M&A, wealth management, tax litigation, and compliance. The group is led by tax and transfer pricing partners Ciro Meza and Gustavo Sánchez. Although the firm works across many industries, the team specializes in oil and gas matters.

The recent activity of the transfer pricing team’s practice is confidential in nature.

Brigard Urrutia

The tax team at Brigard Urruitia has a high level of expertise in the areas of international and national tax planning, and tax litigation throughout Colombia. The practice is led by a team of three partners: Lucas Moreno, Andrés Hernández, and Catalina Jaramillo. The firm serves both domestic and foreign investors, with the intention of promoting Colombia’s development.

The recent activity of the transfer pricing team’s practice is confidential in nature.

Dentons Cardenas & Cardenas

Dentons Cardenas & Cardenas is a transfer pricing driven group which supports the preparation, filing, and compliance of formal obligations for clients across Latin America and the Caribbean region. The team has experience working across many industries including textile manufacturing, IT services, and mining.

Over the research period, the group consulted the Colombian subsidiary of the Yildirim Group. The matter included an analysis of the mandatory registration of commodity transaction agreements before local tax authorities. The firm conducted a complex analysis in order to determine if the transaction involved a commodity product according to Colombia's local transfer pricing regulations.

DLA Piper Martinez Beltran

Founded in 1996, DLA Piper Martinez has been recognized for its handling of complex tax advisory and litigation matters. The group specializes in tax law, tax structuring, estate planning, tax litigation, and tax incentives related to foreign investment and international trade.

The transfer pricing team provides specialized support to the firm’s collection of regular clients. It recently represented Grupo Mexichem (now ORBIA) in multiple lawsuits against the Colombian Tax Administration regarding the value of its taxable income. This litigation was challenging considering the technical transfer pricing issues involved in the matter. Still, the team was able to obtain a series of successful decisions for the client without having to go to court.

César Cermeño joined the firm in February of 2020 after previously working with Garrigues.

EY

EY’s Colombian tax group is comprised of three hundred and seventy members across four offices. The team assists foreign clients investing in Colombia, especially in the areas of large acquisitions and reorganizations. The firm has focused efforts on Tax Technology solutions, taking a leading role in developing electronic invoices and payroll.

The transfer pricing team provides specialized support to the firm’s collection of regular clients. It acted as transfer pricing advisor in a controversy related to intercompany transactions. The Tax Authority had challenged the characterization of the services received by the client and their compliance with the registration of agreements which allow the deduction of such expenses. The matter set precedents in relation to the amount and quality of financial information which can be used in transfer pricing analysis.

In April of 2020, the firm added Carlos González to its partnership. González was hired by Contexto Legal.

FT Consultants

FTC Consultants was established in September of 2021. Headquartered in Bogota, Colombia. The firm provides services in transactional tax, tax planning, and national and international taxation. The group specializes in the digital economy, and consumer goods and services industries.

The recent activity of the transfer pricing team’s practice is confidential in nature.

The firm welcomed Hector Falla as a partner in September of 2021. Fella had previously worked for Deloitte Colombia.

GodoyHoyos_Goh

GodoyHoyos_Goh, founded in 2004, provides legal services related to tax planning, tax structuring of transactions, tax compliance, transfer pricing, and representation before the tax administration. The team is particularly active in the industries of energy, infrastructure, financial markets, and insurance. Catalina Hoyos Jiménez heads the tax department.

The transfer pricing team provides specialized support to many large corporations. Recently, the practice advised the The Louis-Dreyfus Group. The matter related to the determination as to whether the sales price of raw materials to a foreign party was in accordance with market values, in the application of transfer pricing rules. Local tax authorities have prevented the company from correcting its statements, thus causing a negative impact on its local operations. This led to the filing of additional lawsuits by the firm on behalf of The Louis-Dreyfus Group.

Gómez-Pinzón Abogados

The independent practice of Gómez-Pinzón Abogados houses a tax department with a total of fourteen lawyers, including three partners. The group provides a full-service tax experience, with an emphasis on the areas of tax litigation, M&A tax planning, and corporate restructurings. The department is led by Mauricio Piñeros.

The recent activity of the transfer pricing team’s practice is confidential in nature.

Philippi Prietocarrizosa Ferrero DU & Uría

Martín Acero and Carolina Rozo co-head the tax practice of fifteen associates at Philippi Prietocarrizosa Ferrero DU & Uría. The firm has a regional presence in Colombia, Chile, and Peru. The local team excels in international reorganizations, local and offshore tax planning, private clients, and tax litigation. The firm additionally houses an internal team which specializes in transfer pricing. It advises on litigation and assists the tax team by providing guidance regarding transactions that involve foreign parties.  

The transfer pricing team’s support enhances the firm’s corporate advisory services. An example of its expertise is the group's development of asset transfer strategies and an assessment of the tax effects from the sale of Termoyopal and Termovalle. This included an analysis of cross-border mergers, and the economic impact derived from the currency exchange on the transactions. This matter was made difficult because it entailed simplifying the corporate and tax structure implemented in an international deal.

SanintRivas

SanintRivas advises clients on the dynamics of Colombian and international tax regulatory environment within the context of their business operations. The transfer pricing team focuses on providing clients with strategic advice related to how to set a comprehensive transfer policy, meeting requirements regarding compliance matters, and preparing for tax audits. Key contacts at the firm are Laura Sanint and Daniela Rivas.

Over the research period, the firm advised Frubana, an emerging technology group which services large consumers, on the critical transfer pricing policies related to the development of the business. The group is continuing to support the company as they develop their transfer pricing structures.  

TPC Group

TPC Group is an International Transfer Pricing and Consulting Firm, made up of a network of strategic partners in Latin America, the USA and Spain. The group specializes in transfer pricing consulting; however, it also provides tax planning services to multinational groups.

Over the research period, the Colombian office provided services to multiple large corporate entities which aimed to avoid future tax contingencies.