Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

Baker McKenzie in Colombia offers services in consultancy, compliance with formal obligations, documentation, disputes and transfer pricing controversies. It has also advised on local and regional projects in Latin America.

Gustavo Sanchez-Gonzalez is a senior economist and the head of the transfer pricing practice at the firm. His expertise includes the financial and economic valuation of shares, litigation and tax efficient transfer pricing policies. He also counsels companies on various aspects of transfer pricing from different sectors in South and Central America.

The team’s recent experience is highlighted in its representation of Corporacion GPF in an APA negotiation with the Ecuadorian tax administration. The case included a deductibility threshold for intercompany payments of royalties, technical services, administrative services and consulting services. For the average taxpayer, this represents a potential deductibility problem of around $12.5 million, therefore an APA was pursued in order to obtain a higher deductibility threshold.

The firm recently welcomed Laura Duran as a middle associate in Colombia.


BaseFirma is a leading transfer pricing specialist firm in Colombia. Its transfer pricing division has of three partners including practice lead Diana Mogollon. It employs 12 other tax professionals including Monica Santa, who joined the firm in March 2017.

Due to the firm’s strong industry specialism in transfer pricing, it is able to provide innovative and up-to-date consulting services. Its professionals assist clients with setting and implementing transfer pricing policies, structuring business models, Country-by-Country Reporting and BEPS analysis. It has also been involved in the development of transfer pricing audit defences.

The team’s recent experience in Colombia is shown in its counselling of a leading processed food company in Colombia. It provided advice on whether APAs should be subscribed, and the case proved tricky because it involved more than 70 companies and the group’s whole network of intercompany transactions. It reviewed all the types of transactions and decided whether APAs should be subscribed in over 20 countries.

The team recently welcomed Carolina Zuluaga as an account manager in Colombia.

Brigard & Urrutia Abogados

Brigard & Urrutia Abogados is a leading law firm in Colombia. Its transfer pricing practice consists of two partners and eight other tax professionals. It advises clients in all areas of transfer pricing. Its services have helped companies develop and implement economically sustainable transfer prices through consultancy, transfer pricing planning and litigation.

The team’s recent experience in transfer pricing matters as well as general corporate tax is exhibited in its representation of Dolphin Drilling Group and was requested to coordinate different tax issues with the client’s tax advisors in other jurisdictions including the UK. The team advised the client on different aspects including tax planning in Colombia to operate in an offshore free-trade zone, transfer pricing analysis, day-to-day operations and all matters related to 220 expatriates working on the project. The team also performed a permanent establishment analysis in which a study of a profit attribution was made.

The firm recently welcomed Ricardo Beltran as the new transfer pricing lead, as well as Daniel Duque as an associate.


The transfer pricing practice of the Colombia office of international consultancy Deloitte is recognised for its proficiency in both planning, consulting and controversy matters. It regularly advises major national and international clients from a wide range of industries.

Recent work highlights have included advising a client in the mining sector in relation to a start-up process the company is going through and assisting a regional oil and gas group in the reorganisation of its international structure.

The most significant change to the team this year saw the addition of partner Bruno Urrieta to the practice, who joined from Deloitte's Mexico operation.


Garrigues in Colombia has grown in recent years and, notably, its customs and international trade practice has grown steadily. It is particularly active in customs controversies and free-trade zone qualifications.

The team recently welcomed Maria Isabel Espinel as the transfer pricing Latam head, as well as Julio Cesar Toro, Maria Paz Arroyave. And Andrea Mendez as senior associates.

Godoy & Hoyos Abogados

Godoy & Hoyos Abogados is made up of four professionals. Catalina Hoyos is the firm's director and Mónica Hernández is the firm's transfer pricing manager.

This year, the firm represented Perfilamos del Cauca before the tax authority in a dispute relating to the validity of a transfer pricing study filed by the company. In this case, the team, alongside ally firm Élan Zaak (Mexico), prepared an expert report in order to support the study.

In another deal, the firm led the process of attributing profits applicable to Colombian permanent establishments. In this matter, It determined the parameters under which foreign enterprises with permanent establishments pay taxes in Colombia.

The firm's client list includes Catlin Insurance Company, Hannover Re and Avanxo.

The team recently welcomed Maria Camila Bobadilla, Santiago Pineda, Edwin Villalobos and Alejandro Herrera as associates.

Philippi Prietocarrizosa Ferrero DU & Uría

Philippi Prietocarrizosa Ferrero DU & Uría is comprised of two partners and two other fee earners. The firm's transfer pricing practice provides services in the preparation of economic and transfer pricing analysis, the structuring of transnational operations, consultancy in tax and corporate planning, among other things. Sandra Pineda heads the transfer pricing practice.

The firm’s recent experience in transfer pricing and transactional tax matters is exhibited in its representation of Drypers Andina/Protisa Colombia in designing a legal structure to render different services between the companies of the group in order to make the particular intercompany operations feasible enough to be performed both in Colombia and abroad.